Article 227 jurisdiction against interlocutory arbitral orders is minimal; grievances must wait for final award challenge.

The Petitioner and Respondent are equal partners in M/s Agronext Ventures LLP.

Following a partnership dispute, the Respondent initiated arbitration proceedings on 10.10.2023 for money recovery and the Petitioner’s expulsion.

During the proceedings, the Petitioner sought to introduce additional documents as secondary evidence, specifically a police closure report dated 04.12.2023 and an NCLT order dated 25.07.2025.

The sole arbitrator passed impugned orders on 26.06.2025 and 13.02.2026 rejecting these applications on the grounds of irrelevance.

The Petitioner challenged these interlocutory orders before the High Court under Article 227 of the Constitution of India.

Whether the High Court should exercise its jurisdiction under Article 227 of the Constitution to interfere with interlocutory orders passed by an Arbitral Tribunal regarding the admissibility of evidence.

The Court applied the principle of minimal judicial interference in arbitral proceedings under Article 227 of the Constitution of India.

Article 227 jurisdiction against interlocutory arbitral orders is reserved only for "palpable illegality" to prevent the reintroduction of traditional litigation mechanisms into private ADR.

Intermittent challenges to arbitral orders are not envisaged by the Arbitration and Conciliation Act, 1996 (A&C Act), except as provided under Section 37; otherwise, aggrieved parties must wait to challenge "in-between" orders under Section 34 after the final award is passed.

The Court reasoned that since arbitration is a voluntary, private adjudicatory system chosen by parties to opt out of conventional court mechanisms, the judiciary must not "casually" entertain writs against interlocutory orders.

The Court observed that the scope of Article 227 in such matters is minimal and found no justification for interference at this interlocutory stage.

The Court emphasized that the Petitioner is not left without a remedy, as any grievance regarding the rejection of evidence can be agitated under Section 34 of the A&C Act once the final award is pronounced.

Consequently, the Court found the Petitioner’s submissions insufficient to warrant an exception to the rule of non-interference.

The petition was dismissed. The Petitioner was granted liberty to challenge the correctness of the impugned orders under Section 34 of the A&C Act if they remain aggrieved by the final award.