Facts/Background:

• Deccan Paper Mills Co. Ltd. (Deccan) was the Appellant.
• M/s Ashray Premises Pvt. Ltd. (Ashray), Regency Mahavir Properties (Regency), and Mr Atul Chordia (Respondent No. 3) were the Respondent of the case.
• Deccan and Ashray entered into an agreement for land development on 22.07.2004, allowing Ashray to assign rights. On 20.05.2006, Ashray assigned rights to Regency with an arbitration clause.
• Deccan alleged fraud by Mr Atul Chordia, representing Regency, who misrepresented himself as an authorised partner. Deccan filed Special Civil Suit No. 1400 of 2010, seeking cancellation of the agreements based on fraud.
• On 19.07.2010, Regency filed an application under Section 8 of the Arbitration and Conciliation Act seeking a referral to arbitration. Deccan opposed this, citing the unenforceability of the arbitration clause due to fraud.
• On 19.07.2011, the Civil Judge, Senior Division, Pune, referred the dispute to arbitration and upheld the arbitration clause's enforceability despite the fraud allegations.
• Deccan filed a writ petition challenging the trial court’s decision. On 18.03.2015, the Bombay High Court upheld the arbitration clause’s enforceability, dismissing the petition and applying the Swiss Timing Ltd. v. Commonwealth Games 2010 Organising Committee (2014) 6 SCC 677.
• Hence, the present appeal.
  

Main Issue:

• Whether proceedings under Section 31 of the Specific Relief Act, 1963 classified as proceedings in rem or in personam?