Supervisory review over interlocutory arbitral orders is limited; non-appealable rulings should usually await a Section 34 challenge.

Article 227 supervisory jurisdiction over an interlocutory arbitral order refusing additional documents is to be exercised sparingly, only to correct patent perversity, gross failure of justice, or breach of natural justice. Because the Arbitration and Conciliation Act, 1996 adopts minimal judicial intervention and provides appeal only for orders made appealable under Section 37, such non-appealable tribunal orders are ordinarily to be challenged after the award in proceedings under Section 34. No exceptional ground for interference was shown, so the revision was not maintainable and interference was declined.

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Issues: Whether a revision under Article 227 of the Constitution of India was maintainable against an interlocutory order of the Arbitral Tribunal refusing to accept additional documents, and whether such interference was warranted in view of the scheme of the Arbitration and Conciliation Act, 1996.

Analysis: The supervisory power under Article 227 is to be exercised sparingly and only to keep subordinate fora within the bounds of their authority or to correct patent perversity, gross failure of justice, or violation of natural justice. The order under challenge was an interlocutory order passed in arbitral proceedings between private parties. The scheme of the Arbitration and Conciliation Act, 1996 emphasizes minimal judicial intervention, and orders of the tribunal other than those made appealable under Section 37 are ordinarily to be challenged only after the award is made, in a proceeding under Section 34. In the facts of the case, no exceptional ground justifying interference was made out.

Conclusion: The revision was held not maintainable and interference under Article 227 was declined.

Final Conclusion: The challenge to the arbitral tribunal's interlocutory order was rejected, and the proceeding was dismissed without costs.

Ratio Decidendi: A High Court should not interfere under Article 227 with an interlocutory arbitral order except in exceptional circumstances, and the Arbitration and Conciliation Act, 1996 requires parties to await the award unless the order is specifically appealable.

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