Supervisory jurisdiction and arbitral interlocutory orders are barred except in rare exceptional cases under the Arbitration Act.

Article 227 supervisory jurisdiction is generally unavailable to challenge an interlocutory arbitral order rejecting additional documents, because the Arbitration and Conciliation Act, 1996 confines appeals to the specific situations in Section 37. The impugned order was not an interim award, so Section 34 was not yet available. Judicial interference in ongoing arbitration is reserved for rare exceptional cases, such as bad faith or complete absence of an effective remedy, and those limits were not met here.

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Issues: Whether a petition under Article 227 of the Constitution of India is maintainable to challenge an interlocutory order of an arbitral tribunal rejecting an application to place additional documents on record.

Analysis: The governing scheme of the Arbitration and Conciliation Act, 1996 restricts judicial interference with ongoing arbitral proceedings. Appeals lie from arbitral tribunal orders only in the situations specifically provided by Section 37, and an interlocutory order of the kind impugned here, passed on an application under Order VII Rule 14 of the Code of Civil Procedure, 1908, does not fall within those categories. The availability of a challenge under Section 34 is confined to an arbitral award, including an interim award, and the impugned order is not an interim award within Section 2(1)(c) read with Section 31(6). The cited authorities were read as reinforcing the principle that writ or supervisory jurisdiction is not to be used to interrupt the arbitral stream except in rare and exceptional cases of bad faith or where the party would otherwise be left remediless, which was not shown here.

Conclusion: The petition under Article 227 was not maintainable and could not be entertained against the impugned interlocutory arbitral order.

Ratio Decidendi: Interlocutory orders of an arbitral tribunal are not amenable to challenge under Articles 226 or 227 unless the Act specifically permits appeal or the exceptional limits for supervisory intervention are clearly made out; otherwise, the aggrieved party must await the statutory challenge to the award.

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