Arbitrable Disputes Under Section 31 of Specific Relief Act Are Not Binding On Third Parties : Calcutta HC

The Calcutta High Court held that disputes concerning the cancellation of written instruments under Section 31 of the Specific Relief Act, 1963, are arbitrable. 

However, it emphasized that arbitral awards arising from such disputes are binding only on the parties involved and not on third parties who were not part of the arbitral proceedings.​

This decision arose from a case in which the petitioner challenged the Kolkata Municipal Corporation's refusal to de-amalgamate premises, citing an arbitral award that had canceled a Deed of Exchange. The Corporation maintained that the deed remained valid, as it was not a party to the arbitration.

The High Court upheld this stance, reinforcing the principle that arbitral awards cannot impose obligations on non-parties.