Section 34 challenges against interim and final awards must be consolidated to avoid fragmented adjudication.

The petitioners (original claimants) were involved in 15 consolidated arbitration references concerning the "Bidiwala Group"

On March 25, 2024, the Sole Arbitrator passed an interim final award on liability, which was challenged by the respondents under Section 34 of the Arbitration and Conciliation Act, 1996, in the Commercial Court, Ahmedabad (C.M.A. No. 73 of 2024)

Subsequently, on March 12, 2026, a final common award on quantum was pronounced

The petitioners sought to avoid piecemeal adjudication and conflicting decisions by requesting that the challenges to both the interim and final awards be heard together

The petitioners filed an undertaking stating they would not enforce the final award dated March 12, 2026, during the pendency of the Section 34 proceedings, provided the respondents challenged the final award within the statutory three-month period

1. Whether the Section 34 applications challenging the interim award on liability and the final award on quantum should be clubbed and heard together to avoid fragmented adjudication.

2. Whether the petitioners’ undertaking regarding the non-enforcement of the final award should be recorded as a condition for such consolidated proceedings.

Section 34 and Section 34(3) of the Arbitration and Conciliation Act, 1996, which govern the challenge to arbitral awards and the three-month statutory limitation period for filing such challenges

Principles established by the Supreme Court in Indian Farmers Fertilizers Co-operative Limited v. Bhadra Products (2018 2 SCC 534), which cautions against the "mischief of piecemeal and fragmented adjudication" in arbitration proceedings

The Court observed that since the interim award on liability and the final award on quantum arose from common arbitration references, deciding them separately could lead to a multiplicity of proceedings and conflicting outcomes

By applying the doctrine from IFFCO v. Bhadra Products, the Court emphasized that consolidated hearing at the Section 34 stage is ideal when different stages of the award are challenged

The Court accepted the petitioners' conditional undertaking as a balanced measure: it protects the respondents from enforcement of the quantum award while the liability issue is still under challenge, provided the respondents act within the statutory timeline of three months under Section 34(3)

The Court noted that the parties were ad idem (in agreement) regarding the consolidated hearing

The Court recorded the petitioners' undertaking not to initiate enforcement proceedings for the final award during the pendency of the consolidated Section 34 applications

The Commercial Court was directed to decide the matters in a time-bound manner without unnecessary adjournments. The petitions were disposed of accordingly