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Supreme Court of India 2021-02-11 allowed

CHINTELS INDIA LTD vs BHAYANA BUILDERS PVT. LTD

Bench: 3 — R. F. Nariman, Navin Sinha, K.M. Joseph

In Brief

Chintels India challenged the Delhi High Court's dismissal of its appeal from an order refusing to condone delay in filing a section 34 petition under the Arbitration Act 1996 to set aside an arbitral award. The Supreme Court held that such refusals are appealable orders under section 37(1)(c). The Court reasoned that section 37(1)(c) applies to refusals "under section 34"—meaning the entire section, including section 34(3) which governs limitation and delay condonation. When a court refuses to condone delay, it effectively refuses to set aside the award. The "effect doctrine" is built into section 37 itself. The Court overruled contrary High Court judgments and allowed the appeal, remitting the matter for substantive reconsideration.

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Arbitration and Conciliation Arbitration Act 1996 Appealability Condonation of Delay Limitation Section 37 Civil Procedure

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