BANWARI LAL KOTIYA vs P.C. AGGARWAL

The Supreme Court held that under the Arbitration Act, 1940, specifically Sections 2(a), 2(e), and 20, a valid arbitration reference requires the consent of both parties, and a unilateral reference is insufficient. The Court found that the respondent, despite signing the Contract Notes, did not consent to the actual reference as he failed to nominate an arbitrator, rendering the reference unilateral. Consequently, the Court upheld the Full Bench's decision that the respondent was not bound by the arbitration award, leading to the dismissal of the appellant's claim.