Dr. S. B. DUTT vs UNIVERSITY OF DELHI

The Supreme Court held that the award made under Section 45 of the Delhi University Act, 1922, which declared the appellant's dismissal as ultra vires and mala fide, contained an error on its face and was thus set aside. The Court clarified that an award enforcing a contract of personal service is not valid if it contradicts the provisions of the Arbitration Act, 1940, and cannot include disputes relating to reinstatement. The Court distinguished this case from previous rulings, emphasizing that the terms of the Delhi University Act do not authorize such directions by an arbitrator.