New Pleadings or Evidence at the stage of Appeal
1 New facts, which has no foundation at original proceedings, cannot be introduced u/s 34 to challenge the Award.
2 A Plea of Non-Jurisdiction of private Arbitration, on the premise of applicability of Statutory Arbitration, cannot be raised for the first time in Appeal.
3 Section 34 Application is to be decided on the basis of Record that was before Arbitrator, and additional material / evidence should not be allowed unless absolutely necessary.