NARAYAN PRASAD LOHIA vs NIKUNJ KUMAR LOHIA .

The Supreme Court addressed the issue of whether a mandatory provision of the Arbitration and Conciliation Act, 1996 can be waived by the parties involved in arbitration. The Court noted that the previous judgment in Dodsal Private Ltd. vs. Delhi Electric Supply Undertaking raised similar questions but did not resolve the issue, leading to the referral of this matter to a larger bench for clarification. The Court held that the question of waiver of mandatory provisions is significant and requires further examination by a bench of at least three judges.