Writ jurisdiction against arbitral orders requires manifest lack of inherent jurisdiction or absence of alternative statutory remedy.

The parties entered into a contract on May 8, 2018, for pipeline works in Ranchi.

Disputes regarding site handover and route maps led the Appellant to invoke arbitration on November 23, 2023

During proceedings, the Respondent terminated the contract on March 29, 2025

After the Appellant’s primary witness underwent cross-examination between July 28 and July 31, 2025, the Appellant moved an application on August 12, 2025, to introduce additional documents (Volume VI)

The Arbitral Tribunal rejected this and subsequent applications, observing that the Appellant sought to fill evidentiary lacunae mid-cross-examination

The Appellant challenged these procedural orders via a Writ Petition.

A Single Judge dismissed the petition on January 20, 2026, holding that the Tribunal is the master of its own procedure and the applications were belated

The Appellant filed the present Letters Patent Appeal (LPA) asserting a violation of natural justice and procedural flexibility

1. Whether the facts of the case constitute "exceptional circumstances" warranting the exercise of writ jurisdiction under Articles 226 and 227 of the Constitution of India against an interim procedural order of an Arbitral Tribunal.

2. Whether the Appellant is left remediless by the Tribunal’s refusal to admit additional evidence at the cross-examination stage.

The Court applied Section 5 of the Arbitration and Conciliation Act, 1996, which limits judicial intervention to instances explicitly provided in Part I of the Act

It relied on the "self-contained code" principle from Deep Industries Limited v. ONGC, establishing that writ jurisdiction is reserved for cases of "manifest lack of inherent jurisdiction"

The Court further applied the "exceptional circumstances" test from Bhaven Construction v. Executive Engineer, which restricts interference to cases where a party is left without a statutory remedy or there is clear bad faith

Finally, it cited Section 34(2)(a)(iii) of the Arbitration Act, which allows an award to be set aside if a party was "otherwise unable to present his case"

The Court reasoned that the Arbitral Tribunal exercised its rightful discretion in rejecting the applications to avoid inordinate delay and to prevent the Appellant from rectifying gaps in evidence during an ongoing cross-examination

It held that procedural autonomy belongs to the Tribunal, and the Appellant’s participation in the application process acknowledged the Tribunal's jurisdiction; therefore, a negative outcome does not equate to a "lack of inherent jurisdiction"

The Court emphasized that judicial restraint is essential to maintain the efficiency of arbitration

Furthermore, it noted that the Appellant failed to prove "bad faith" or "exceptional circumstances" as defined in Deep Industries and Bhaven Construction

The Court highlighted that the challenge did not meet the high threshold required to bypass the statutory framework of the Arbitration Act

It ruled that the Appellant is not remediless, as the procedural grievance regarding the inability to present evidence can be raised as a ground to challenge the final award under Section 34(2)(a)(iii) of the Arbitration Act

The Court found no infirmity in the Single Judge’s order and affirmed that the Tribunal’s decision was well-reasoned and within its prerogative