In the captioned case, the arbitral award was pronounced in a virtual hearing attended by advocates of both parties. A signed copy of the award was emailed to the advocates on the same day.

A challenge under Section 34 was filed beyond the 3-month limitation period. It was argued that service of the award through email did not amount to valid delivery under Section 31(5) of the Act and that the limitation period should run from the date of receiving the physical copy.

Ruling

The Court reaffirmed that "signed copy" includes the original award and authenticated electronic versions. Service of an award through email satisfies the requirements of Section 31(5). Delivery of the signed copy by an Arbitral Institution on behalf of the Tribunal to parties and/or their authorized counsel shall be valid service.