An arbitration clause referring to every dispute relating to interpretation and performance of the contract does not include a claim for damages based on non-performance of the arbitral award, because, despite the breadth of its formulation, it is still referred to the contract and not to the award - an ontologically different and autonomous title on which the damages claim is based.
In contractual arbitration proceedings, failure to observe adversarial procedure is not a formal defect but one of activity. The nullity that flows from it implies concrete compression of the procedural party's right of defence, requiring regard to the way parties could confront each other in judgment in relation to claims made there.
A contractual arbitral award may be challenged for error only when formation of arbitrators' will was deviated by altered perception or false representation of reality and factual elements submitted to their examination, not for errors of law or erroneous evaluation of reality whose elements were exactly perceived.
A contractual arbitral award is not challengeable for errors in judging, even where these consist in erroneous interpretation of the contract made by parties that gave rise to the mandate to arbitrators, nor for erroneous application of contractual interpretation rules or for appreciation of contractual findings different from that considered by arbitrators.