Mandatory arbitral timelines can invalidate an appellate award when the prescribed extension expires and the delay offends public policy.

An appellate arbitral award was held vulnerable to challenge under Section 34 because it was rendered after the mandatory time limit prescribed by the institutional bye-laws and SEBI circular had expired. The framework allowed only a three-month period, with a limited two-month extension, and the award was made beyond that extended period. The Court treated the timeline as mandatory in light of its wording and the object of expeditious arbitration, and held that participation in the proceedings and filing written submissions did not amount to waiver of the objection. The delay was found contrary to public policy and sufficient to justify interference.

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Issues: Whether the appellate arbitral award was liable to be set aside under Section 34 on the ground that it was rendered beyond the prescribed time limits under the NSE Bye-Laws and the SEBI circular, and whether the delay rendered the award void and contrary to public policy.

Analysis: The challenge was confined to the validity of the appellate award, the original award not being examined on merits. The applicable framework required the appellate tribunal to dispose of the appeal within three months from appointment, with a limited extension of two months. The award was made after the extended period had expired. The Court held that the use of mandatory language in the bye-law and circular, read with the object of expeditious arbitration, showed that the timeline could not be ignored. It further held that participation in the proceedings and filing of written submissions did not amount to waiver of the objection to the tribunal's mandate. Delay of this nature was held to defeat the public policy of speedy dispute resolution and to furnish a ground for interference under Section 34.

Conclusion: The appellate award was set aside as having been passed beyond the permissible time limit and as being contrary to public policy.

Ratio Decidendi: Where an institutional arbitration framework prescribes a mandatory time limit for disposal of an appeal and permits only a limited extension, an award made beyond that period is vulnerable to challenge under Section 34 as contrary to public policy, and participation in the proceedings does not by itself amount to waiver of the objection.

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