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Supreme Court of India 2018-01-23 allowed

Indian Farmers Fertilizer Co-Operative Limited vs Bhadra Products

Bench: 2 — R.F. Nariman

In Brief

A fertilizer company challenged a defoamer supplier's arbitral award on limitation as an interim award under Section 34 of the Arbitration and Conciliation Act, 1996. The arbitrator had decided the limitation question first, marking it a 'First Partial Award'. The courts below held this was not an interim award. The Supreme Court allowed the appeal, holding that an award finally deciding one matter between parties (even preliminarily) is an interim award challengeable under Section 34. The Court clarified that 'jurisdiction' in Section 16 means only the tribunal's own competence (arbitration agreement validity, constitution, scope)—not preliminary substantive questions like limitation, which are merits-based findings open to Section 34 challenge separately from the final award.

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Arbitration Interim Awards Limitation Section 34 Challenges Jurisdiction of Arbitral Tribunal Partial Awards

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