Arbitration arises from a contract and unless there is a specific written contract, a contract with regard to arbitration cannot be presumed. Section 7 (3) of the Arbitration and Conciliation Act clearly specifies that the contract with regard to arbitration must be in writing. If a non-arbitrable dispute is referred to an arbitrator and even if an issue is framed by the arbitrator in relation to such a dispute, there cannot be a presumption or a conclusion to the effect that the parties had agreed to refer the issue to the arbitrator. It is not open to the arbitrator to decide the issues which are not arbitrable and the award, so far as it relates to disputes regarding non-arbitrable disputes is concerned, is bad in law. Harsha Constructions v. Union of India, (2014) 9 SCC 246.