STATE OF ORISSA vs NIRIPAMA SWAIN — C.A. No. 466 - 469/2001

Case Summary: Manohar Lal v. Vinesh Anand & Ors. (C.A. No. 466/2001) Decision: The Supreme Court dismissed the appeal, holding that an arbitrator is NOT a "Court" within the meaning of Section 195(3) of the Criminal Procedure Code, and therefore Section 340 CrPC (procedure for prosecuting offences committed in court proceedings) does not apply to arbitral proceedings. Key Reasoning: The Court emphasized that Section 195(3) explicitly restricts the definition of "Court" to Civil, Revenue, or Criminal Courts, and includes tribunals only if specifically declared by statute to be a court. Since the Arbitration and Conciliation Act, 1996 contains no such declaration, arbitrators fall outside this definition. The Court rejected arguments based on arbitrators' quasi-judicial powers, concluding that the legislative intent to minimize court interference in arbitration does not equate to granting arbitrators the formal status of courts under criminal procedure law. This case analysis is maintained by casestatus.in based on publicly available court records.