In a recent order, a single judge of the Calcutta High Court in Jagdish Kishinchand Valecha v. SREI Equipment Finance Ltd. (13 April 2021) made an important clarification on the question of whether a court could appoint a different arbitrator, where an arbitral award made by the original arbitrator is set-aside under section 34 of the Arbitration and Conciliation Act, 1996 (“Act”) on grounds of ‘bias’ or ‘conflict of interest’ on the part of the original arbitrator.