Hybrid Award

Hybrid award, which are neither speaking awards nor non-speaking - partly speaking and partly non-speaking awards. If the award made by the arbitrator is a non-speaking one the difficulty of showing that there is an error apparent on the face of the award becomes insurmountable and ordinarily such award cannot be challenged at all unless it is shown that the arbitrator has wholly travelled outside the contract which gives him the jurisdiction. In cases of speaking awards the court can interfere if there is an error apparent on the face of the award itself, Bharat Coking Coal Ltd. v. .K. Ahuja and Co., IR 2001 SC 1179 (1182): (2001) 4 SCC 86.