Arbitration and Conciliation Act, 1996: s.15(2) — Appointment of substitute arbitrator on resignation of named arbitrator — Applicability of s.15(2) when arbitrator to whom the matter was referred earlier with the consent of the parties withdraws therefrom — Held: If arbitration agreement that was arrived at between the parties did not specifically bar the appointment of another arbitrator on the withdrawal of earlier arbitrator appointed by the parties with mutual agreement, s.15(2) of the Act would be attracted and a substitute arbitrator could be appointed — Courts have the power to appoint substitute arbitrator, which power is given by s.15(2) of the Act as this provision is to be given liberal interpretation so as to apply to all possible circumstances under which the mandate of the earlier arbitrator may be terminated ~ Arbitration Act, 1940-s.8.

Interpretation of statutes: Purposive interpretation - Held: Though literal rule of interpretation, till some time ago, was treated as the ‘golden rule’, it is now the doctrine of purposive interpretation which is predominant, particularly in those cases where literal interpretation may not serve the purpose or may lead to absurdity — If it brings about an end which is at variance with the purpose of statute, that cannot be countenanced. :