The Bombay High Court, in Nilesh Shejwal case, held that due to a shift in the field of contemporary arbitration, where disputes involving fraud were deemed unsuitable for arbitration, arbitral tribunals are now known to review vast volumes of evidence in a wide range of dispute situations. Thus, it concluded that the antiquated notion that fraud cannot be arbitrated due to its complexity is obsolete and does not apply to modern arbitration processes. This Connect analyses the judgment and reasoning of the High Court.