In several cases, the parties have attempted to impose settlement agreements negotiated under the Act. The pioneering judgment was delivered by the Hon`ble Delhi High Court of Shri Ravi Aggarwal v. Shri Anil Jagota (2009) SCC Online Del 1475. In this case, the parties had entered into a settlement agreement on private mediation and requested enforcement under sections 30, 73 and 74 of the Act. The Tribunal objected on the ground that Part III of the Act applied only to settlement agreements concluded in the context of duly reasoned conciliation proceedings. While private mediation suffers from the lack of legal recognition, the picture is not as bright even though settlement agreements are treated as arbitral awards.