Determinable commercial contract cannot be continued by injunction after expiry; renewal depends on express contractual discretion.

A fixed-term commercial dealership contract could not be continued by interim injunction under Section 9 of the Arbitration and Conciliation Act after expiry, because renewal depended on the respondent's sole discretion and acceptable terms. Relief that would effectively specific-enforce a determinable contract was barred by Sections 14(a), 14(c) and 41(e) of the Specific Relief Act, and any grievance was confined to damages if wrongful non-renewal were proved. Legitimate expectation and promissory estoppel were held inapplicable against the express terms of a concluded private contract. The request for renewal, continuation, or any exit window was rejected.

---

---

Issues: Whether, in a petition under Section 9 of the Arbitration and Conciliation Act, 1996, the petitioner was entitled to an interim injunction directing renewal or continuance of a commercial dealership agreement after its fixed term expired, including a short window period for exit.

Analysis: The agreement was a fixed-term commercial contract with an express clause making renewal dependent on the respondent's sole discretion and on terms acceptable to it. The renewal letters accepted by the petitioner reaffirmed that there was no entitlement to continuation or compensation on expiry. The Court held that Section 9 does not permit granting relief that would effectively amount to specific enforcement of a determinable contract. The relief sought was also barred by the principles underlying Sections 14(a) and 14(c) and Section 41(e) of the Specific Relief Act, 1963, because the petitioner could, at best, claim damages if wrongful non-renewal were ultimately established. The doctrines of legitimate expectation and promissory estoppel were held inapplicable in the face of a concluded private contract and its express terms.

Conclusion: The petitioner was not entitled to any injunction or window period extending the contractual relationship beyond expiry; the request for renewal or continuation was rejected.

---