Strict time limit for Section 37 arbitration appeals: delay beyond 120 days defeats the statutory goal of expeditious resolution.

An appeal under Section 37 of the Arbitration and Conciliation Act, 1996 filed beyond 120 days was treated as not entertainable. The Court applied the same strict statutory discipline governing Section 34 proceedings to Section 37 appeals, reasoning that appellate proceedings are a continuation of the original proceedings. It held that allowing delay beyond the prescribed outer limit would undermine the legislative intent of securing expeditious resolution of arbitration matters. On the facts, the Special Leave Petitions were not entertained.

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Issues: Whether an appeal under Section 37 of the Arbitration and Conciliation Act, 1996 filed beyond 120 days from the Section 34 proceedings could be entertained.

Analysis: The Court noted that in an earlier decision on near-identical facts it had allowed the Union's appeal, but the present matter differed because the Division Bench had dismissed the appeal on delay. Emphasising that appellate proceedings are a continuation of the original proceedings, the Court held that the same statutory discipline applicable to Section 34 proceedings must govern appeals under Section 37. A delay beyond 120 days in filing such an appeal would defeat the legislative intent that arbitration matters be concluded with utmost despatch.

Conclusion: An appeal under Section 37 of the Arbitration and Conciliation Act, 1996 filed beyond 120 days ought not to be entertained; the Special Leave Petitions were not entertained on the facts of the case.

Ratio Decidendi: Where the statute prescribes a strict outer limit for challenging an arbitral order, a Section 37 appeal filed beyond 120 days cannot be entertained because appellate proceedings are a continuation of the original proceeding and delay beyond that period defeats the object of expeditious arbitration.

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