Synopsis

This judgment by a Division Bench of the Gujarat High Court disposes of a bunch of writ petitions arising out of arbitration proceedings. The petitioners (original claimants) had obtained an interim final award on liability dated 25.03.2024, which was challenged by the respondents under Section 34 of the Arbitration and Conciliation Act, 1996. Subsequently, a common final award on quantum was passed on 12.03.2026. To avoid piecemeal and fragmented adjudication, the petitioners gave an undertaking not to enforce the final award pending the Section 34 challenges, conditional upon the respondents filing their challenge to the final award within the statutory limitation period. The court directed that if such challenge is filed, the Commercial Court shall club both the pending and the fresh Section 34 applications and hear them together. The impugned order of the Commercial Court was modified accordingly, and the writ petitions were disposed of.

1. Heading for the judgment

Citation: Dhruvkumar Jaswantlal Patel v. Rajnikant Prahladbhai Patel (Decd.) Through Legal Heirs Ashokkumar Prahladbhai Patel & Ors., R/Special Civil Application Nos. 2776/2026 & connected matters, decided on 23.03.2026 (Gujarat High Court - DB)
Coram: Hon'ble The Chief Justice Mrs. Sunita Agarwal and Hon'ble Mr. Justice D.N. Ray (Division Bench)
Core Law: Arbitration and Conciliation Act, 1996 (Sections 34, 36); Civil Procedure Code.

Gujarat High Court directs consolidation of pending and future Section 34 applications arising from interim and final arbitral awards to avoid fragmented adjudication, based on claimant's undertaking not to enforce final award.

2. Legal framework

This judgment deals with the procedure for handling multiple challe

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