Once a final award is issued, the arbitrator becomes functus officio – he/she no longer has jurisdiction over the dispute and may not issue a further award in relation to the arbitration, save for limited exceptions. However, what if an award includes conditions to be met before one party’s liability to pay accrues? The Court of Appeal in Voltas Ltd v York International Pte Ltd found that a conditional award may be a final award, and a tribunal cannot reserve its jurisdiction by implication.