Arbitration and Conciliation Act, 1996 (26 of 1996), Section 25(a), 32(2) – Termination of arbitration proceedings – Whether such order can  be considered as an award -- An order u/s 25(a) does not and cannot amount to an Award as it does not deal with the rights of the parties before the Arbitrator -- Such an order merely terminates the arbitral proceedings on account of the claimant’s default in filing the statement of claim and does not involve any adjudication or determination of the rights or obligations of the parties -- For an order to qualify as an Award, it must decide, either finally or on an interim, an issue forming part of the dispute referred to arbitration -- An order under Section 25(a), being procedural in nature and not addressing the substantive lis between the parties, lacks the essential attributes of an Arbitral Award -- Order terminating the proceedings for non-filing of a statement of claim cannot be considered an award under Sub-section 2 of Section 32.

(Para 16, 19)