JUGGILAL KAMLAPAT vs GENERAL FIBRE DEALERS LTD (AND CONNECTED APPEAL)

The Supreme Court held that under Section 19 of the Arbitration Act, 1940, the arbitrator becomes functus officio after delivering an award; however, this does not preclude further arbitration proceedings if the initial award is set aside and the arbitration agreement remains effective. The Court clarified that the reference to arbitration is not exhausted by the setting aside of the award, allowing for the appointment of a new tribunal to resolve the same dispute. The judgment affirmed the validity of continuing arbitration under the existing agreement despite the annulment of the prior award.