Gayatri Balasamy seeks to avoid the blunt injustice of all-or-nothing review, but its doctrinal scaffolding is built on inference rather than enactment.

The position of law in Electrosteel needs reconsideration, as argued in this post, to make the enforcement process quicker and more efficient, one which allows the award-creditor to enjoy the fruits of their labour.

It remains to be seen whether the court will use its curative power to alter the arbitral award within its power to set it aside under S 34.

The author remarks that in India, the average disposal time of Section 34 applications is alarmingly high and discusses possible solutions.

The Supreme Court must advance an interpretation of second proviso to Section 36(3) based on some guidelines and the scope of Section 34.