An arbitral tribunal is not a court of law. Its orders are not judicial orders. Its functions are not judicial functions. It cannot exercise its power ex debito justitiae. The jurisdiction of the arbitrator being confined to the four-corners of the agreement, he can only pass such an order which may be subject matter of reference.[Â M.D., ARMY WELFARE HOUSING ORGANISATION vs SUMANGAL SERVICES PVT. LTD. (2004) AIR(SC) 1344 ]
