B. SUBBARAMA NAIDU vs B. SIDDAMMA NAIDU & OTHERS

The Supreme Court held that under Section 23(1) of the Arbitration Act, 1940, it is mandatory for the court to specify the time within which the award must be made; however, failure to do so in the order of reference does not invalidate the reference if the time is indicated elsewhere in the proceedings. The court found that the arbitrator's award, which allotted less than half the share to the appellant, could not be set aside merely on that basis unless dishonesty was proven. The appeal challenging the validity of the award was dismissed.