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22. In the present case, the appellants have raised serious issues, which if answered in favour of the appellants would render the award a nullity. The issues involved are as under:

(i) Whether the clause in question constitutes a valid arbitration agreement between the parties or not?
(ii) If the first question is answered in affirmative, whether the appellants or the company were not a member of Paper Merchant Association Regd., Delhi ('PMA') and therefore are not bound by its arbitration mechanism?