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The division bench of the High Court of Delhi on 17 May 2023, in the case of Kotak Mahindra Bank Limited vs. Narendra Kumar Prajapat, held that an arbitral award passed by an arbitrator unilaterally appointed by a party is a nullity and thus, cannot be enforced. INDUSLAW's Padmaja Kaul, Kushagra Sah and Vansh Bhutani provide their insights on the judgement.