SATWANT SINGH SODHI vs STATE OF PUNJAB

The Supreme Court held that the interim award made by the Arbitrator on November 26, 1992, regarding Item No.1 was final and could not be superseded by a subsequent award made on January 28, 1994, as the Arbitrator had become functus officio. The Court emphasized that an award is valid once made and signed, regardless of whether notice was given to the parties. The High Court's decision to treat the interim award as open to correction was found to be erroneous, reinforcing the principle that an interim award cannot be modified except as per Section 13(d) of the Arbitration Act, 1940. The appeal was allowed, restoring the trial court's ruling that the interim award should be made the rule of the court.