ISSUE:
Whether landlord-tenant issues covered by the Transfer of Property Act 1882, are arbitrable under Indian law, and how does the Supreme Court's four-part test influence this determination?
Whether claims of fraud in a dispute constitute it non-arbitrable, and under what conditions do such allegations influence a disagreement's arbitrability?
RULE:
In India, a four-part test is used to evaluate subject matter arbitrability. When the cause of action and/or subject of the dispute (1) relates to actions in rem that do not relate to inferior rights in personam arising from rights in rem, (2) has an erga omnes effect on third-party rights, necessitating centralised adjudication where mutual adjudication would be inappropriate, (3) involves unalienable sovereign and public interest functions of the State, or (4) is expressly or implicitly prohibited, the dispute is not considered arbitrable.