Zenda Infrastructure Ltd acquired land for a national highway project, compensating landowners based on government-determined rates. Dissatisfied with the valuation, the landowners initiated arbitration, but the appointe

The facts of the given situation are similar to the case of The Project Director National Highways of India vs M. Hakeem decided by Supreme Court in 2021. Background: NHAI initiated land acquisition proceedings under the National Highways Act, 1956, for highway development projects. The Special District Revenue Officer (SDRO), acting as the competent authority, determined compensation amounts based on the 'guideline value' of the lands, which often resulted in significantly low valuations. Dissatisfied landowners sought arbitration as provided under Section 3G(5) of the National Highways Act. However, the arbitrators, appointed by the Central Government, upheld the initial compensation amounts. Legal Proceedings: Aggrieved by the arbitral awards, the landowners filed applications under Section 34 of the Arbitration and Conciliation Act, 1996, before the District Courts, seeking to set aside the awards. The District Courts went beyond merely setting aside the awards; they enhanced the compensation amounts. NHAI challenged these decisions before the Madras High Court, which upheld the District Courts' modifications. Subsequently, NHAI appealed to the Supreme Court. Supreme Court's Analysis: The Supreme Court examined the scope of judicial intervention under Section 34 of the Arbitration Act. It emphasized that Section 34 allows courts to set aside an arbitral award only on specific grounds such as fraud, bias, or violation of natural justice principles. The Court clarified that this provision does not grant courts the authority to modify or enhance the award's terms. The legislative intent, as reflected in the Act, is to minimize judicial interference in arbitral proceedings, ensuring that arbitration remains an effective and efficient alternative dispute resolution mechanism. Conclusion: The Supreme Court concluded that while courts have the power to set aside arbitral awards under Section 34, they do not possess the authority to modify them. This decision reinforces the principle of minimal judicial intervention in arbitration, upholding the autonomy and finality of the arbitral process. This case underscores the importance of adhering to the legislative framework governing arbitration in India and clarifies the limited role of courts in arbitral award enforcement. A division bench of the Supreme Court of India ruled in favour of minimal judicial intervention in the case of Project Director, National Highway Authority of India v. M. Hakeem & Anr., (2021) , holding that courts cannot amend, revise, or alter an arbitral judgement under Section 34 of the Arbitration Act. Therefore, Zenda Infrastructure is likely to succeed in this legal battle.