In Sai Babu vs. Clariya Steels Pvt. Ltd. , CIVIL APPEAL NO. 4956 OF 2019, the sole arbitrator terminated proceedings under Section 32(2) (c) i.e. on the ground that the continuation of the proceedings become unnecessary or impossible. Later, he allowed an application by one of the parties seeking recall of the order terminating the proceedings. The Karnataka High Court dismissed the challenged against this ‘recall’ by the Arbitrator.
On appeal, the Supreme Court referring to the judgment in SREI Infrastructure Finance Limited v. Tuff Drilling, held that it has been clearly held that no recall application would, lie in cases covered by section 32(3)
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