Coordinate Bench precedent binds High Court review; pending Supreme Court proceedings did not justify deferring the appeal.

Pendency or even grant of leave in a similar matter before the Supreme Court does not, by itself, require a High Court to defer disposal of its own proceedings; the court rejected the request to keep the appeal in abeyance and did not entertain the delay application. On the merits, objections under Section 34 to the arbitral award were not interfered with because the claims were already covered by earlier coordinate Bench decisions on the same legal questions. Applying judicial discipline, the Court held it was bound by those rulings and found no basis to refer the matter to a larger Bench. The challenge to the award therefore failed and the dismissal of the Section 34 objections was left undisturbed.

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Issues: (i) Whether the appeal deserved to be entertained despite delay, on the ground that similar issues were pending before the Supreme Court and the appellant had earlier pursued a special leave petition. (ii) Whether the objections under Section 34 to the arbitral award warranted interference when the claims were already covered by earlier coordinate Bench decisions.

Issue (i): Whether the appeal deserved to be entertained despite delay, on the ground that similar issues were pending before the Supreme Court and the appellant had earlier pursued a special leave petition.

Analysis: The pending special leave petitions did not justify postponing disposal of the matter. The Court distinguished the reliance on the principle regarding finality of litigation under Section 14 of the Limitation Act, 1963, and held that the mere pendency or even grant of leave in another matter does not require the High Court to keep its own proceedings in abeyance. The Court also noted that the appellant had voluntarily withdrawn the earlier special leave petition to pursue the appellate remedy before the High Court.

Conclusion: The request to defer or stay consideration of the appeal was rejected, and the delay application was not entertained.

Issue (ii): Whether the objections under Section 34 to the arbitral award warranted interference when the claims were already covered by earlier coordinate Bench decisions.

Analysis: The claims allowed by the arbitral tribunal were held to be covered by earlier Division Bench decisions on the same legal questions. The Court applied the rule of judicial discipline and held that it was bound by those coordinate Bench rulings. Since no basis was shown for reference to a larger Bench, and the earlier decisions had already rejected the same contention, no ground existed to interfere with the order dismissing the Section 34 objections.

Conclusion: The challenge to the arbitral award failed, and the objections under Section 34 were not liable to be revived.

Final Conclusion: The appeal failed in entirety and the order dismissing the objections to the arbitral award was allowed to stand.

Ratio Decidendi: A High Court is bound by coordinate Bench decisions on the same issue, and the pendency or grant of leave in a similar matter before the Supreme Court does not, by itself, require the High Court to defer disposal of the case before it.

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