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Justices Sanjiv Khanna and in rem but pertain to subordinate rights in personam that arise from rights in rem. It further held that an award passed in such disputes can be executed and enforced like a decree of the civil court. Such actions normally would not affect third-party rights or have erga omnes affect or require centralized adjudication. An award passed deciding landlord-tenant disputes can be executed and enforced like a decree of the civil court. Landlord-tenant disputes do not relate to inalienable and sovereign functions of the State. The provisions of the Transfer of Property Act do not expressly or by necessary implication bar arbitration. Transfer of Property Act, like all other Acts, has a public purpose, that is, to regulate landlord-tenant relationships and the arbitrator would be bound by the provisions, including provisions which ensure and protect the tenants, the judgment authored by Justice Khanna observed.

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