Manohar Lal vs Vinesh Anand & Ors

The Supreme Court examined the applicability of Section 340 of the Code of Criminal Procedure in arbitration proceedings, distinguishing it from the earlier ruling in Thawardas Pherumal v. Union of India, which stated that an arbitrator is not a court under the Code of Civil Procedure. The Court held that the repeal of the Arbitration Act, 1940 and the enactment of the Arbitration and Conciliation Act, 1996 necessitated a reevaluation of the role of arbitrators, affirming that the provisions of Section 340 CrPC do not apply to arbitration proceedings. The judgment clarifies the evolving nature of arbitration law in India, emphasizing party autonomy and minimal court interference.