STATE OF PUNJAB vs SRI HARDYAL

The Supreme Court held that under Sections 3 and 28(1) of the Arbitration Act, 1940, if no time is specified in the arbitration agreement for the award, the statutory period of four months applies. The Court ruled that participation in arbitration proceedings after the expiry of the statutory period does not amount to an extension of time for making the award. The appeal was allowed, and the case was remanded to the trial Court to determine if the delay in the award could be condoned, establishing that parties are not estopped from challenging an award on the grounds of delay despite their participation.