Narrow judicial review of tribunal injunctions upheld restraint against former agent and refusal to restore contractual ties.

Judicial review of a specialised tribunal's interlocutory orders is narrow, and interference under Articles 226 and 227 lies only where the order is perverse, materially irregular, or breaches natural justice. Applying settled injunction principles, the High Court accepted that TDSAT could restrain an erstwhile agent from falsely holding out authority for the broadcaster while declining interim relief that would effectively restore a terminated contractual relationship. The Court noted that the dispute arose from termination of agency and distribution arrangements, the claimed losses were capable of quantification in damages, and the balance of convenience was plausibly assessed by TDSAT. No ground was found to disturb the interim arrangements.

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Issues: Whether the High Court should interfere under Articles 226 and 227 with the TDSAT's interlocutory orders granting restraint against an erstwhile agent from holding itself out as representing the broadcaster and declining interim relief to the distributor.

Analysis: The jurisdiction of judicial review over interlocutory orders of a specialised tribunal is narrow and interference is warranted only if the order is perverse, materially irregular, or violates natural justice. The TDSAT, acting under the TRAI Act, has wide adjudicatory powers, including powers akin to a civil court, but its interim orders must still be tested on settled principles governing injunctions and the enforceability of contractual rights. The dispute arose from termination of agency/distribution arrangements, and the TDSAT reasoned that continuing the contractual relationship through an interim order would amount to specific performance of a contract that was not specifically enforceable. The Court accepted that the termination disputes and the resulting losses were capable of monetary quantification, that the balance of convenience could reasonably be assessed by the TDSAT, and that the restraint on an erstwhile agent from falsely holding out authority was not perverse. The Court further held that the termination clauses relied upon were not negative covenants in the relevant sense and that, even otherwise, interim enforcement would not justify restoring the contractual relationship.

Conclusion: No ground for interference with the TDSAT's interlocutory orders was made out; the restraint against the former agent and the refusal of interim relief to the petitioners were sustained.

Final Conclusion: The writ petitions failed and the High Court declined to disturb the TDSAT's interim arrangements in both sets of connected matters.

Ratio Decidendi: In judicial review of a specialised tribunal's interlocutory order, the High Court will not interfere merely because another view is possible, and an interim injunction will not be set aside where the tribunal has adopted a plausible balance-of-convenience approach in a contractual agency dispute and the claimed losses are quantifiable in damages.

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