Detailed Breakdown of Gujarat High Court Ruling on Delay in curing registry defects under Section 34 and its impact on arbitration applications

Delay in curing registry defects

Gujarat High Court: In a batch of appeals filed under Section 37 of the Arbitration and Conciliation Act, 1996 (‘the Act’) against the setting aside of the arbitral award passed in favour of the appellants, the Division Bench of Sunita Agarwal*, CJ. and Pranav Trivedi, J., partly allowed the appeals, holding that a delay in curing registry defects under Section 34 of the Arbitration and Conciliation Act, 1996 does not render the application time-barred, provided the application was initially filed within the statutory limitation period.

The Court delved into various aspects of an arbitration proceeding, such as the limitation on Section 34 appeals, the demand of exorbitant fees by the Arbitrator(s), the applicability of the doctrine of severability on arbitral awards, and much more.

Background

In 2015, the Limited Liability Partnership firm, namely C2R Projects LLP (‘the LLP’) was incorporated via an agreement (‘the LLP Agreement’) between respondents 1 and 2 along with another person. The appellant was later added as a partner.

Soon after, the appellant realised that a huge amount of money was withdrawn from the bank accounts of the LLP by respondent 1 for unexplained purposes. This led to a dispute between the two, and the expulsion of respondent 1 from the LLP. The arbitration clause was invoked, and both the appellant and respondent 1 appointed Arbitrators, but the Tribunal could not be formed. Due to various issues, three arbitral tribunals had to be constituted.

The appellant claimed that Rs. 22.19 Crores had to be paid to the LLP because the said amount was embezzled by respondent 1. He further claimed damages worth Rs. 54.15 Crores, legal costs, and pedente lite interest in the arbitral proceedings.

Allegedly, both respondents failed to pay the arbitral fee, so the Arbitral Tribunal passed the award upholding the claims of the appellant. The arbitral award was challenged by the respondents under Section 34 of the Act. The Court allowed the applications and set aside the arbitral award vide the impugned order.

Aggrieved, the appellant filed the present appeal.

Issues and Analysis

A. Preliminary

i. Section 34 applications were grossly time barred – beyond limitation under Section 34(3) of the Act

Regarding the contention that the applications filed by the respondents against the Arbitral Tribunal were time-barred as they were under objection for around 8 months, the Court referred to Chapter XXI in the Gujarat High Court Rules, 1993 (‘the GHC Rules’), which provide that defects must be removed in 14 days from the date of service of the office objection. Rule 268 further provided that any delay beyond one month shall be treated prima facie as failure to prosecute diligently, and such delay may be excused only by the order of the Court.

The Court noted that the registry did not follow the procedure prescribed in the GHC Rules for the movement of the papers from the registry to the competent Court despite the expiry of the time prescribed period thus, there was no occasion for consideration by the Court concerned as to whether the respondents were entitled to get condonation of delay in the removal of office objections. No such occasion arose in the petition filed by respondent 1 wherein a regular number was allotted by the registry with the removal of the defects and the matter was listed before the Court after urgent circulation mentioning. The respondent 2’s petition was posted before the Division Bench having jurisdiction of the First Appeal as the cause title of the case was wrongly stated as First Appeal, and an order was passed by the Court for removal of office objections and permitting conversion of the petition into an application under Section 34 of the Act.

Noting this, the Court stated that it could not be held that the Section 34 applications were liable to be dismissed outrightly for having been filed/presented beyond the period of 120 days prescribed in Section 34(3). The Court held that even otherwise, with the removal of the office objections by the parties presenting a matter by the registry or under the order passed by the Court, the date of removal of office objection would relate back to the date of the presentation or filing of the case. Additionally, the Court held that both the petitions were never dismissed for want of prosecution, for non-removal of the objections.

Thus, the Court held that there was no infirmity in the Court admitting the petitions filed by the respondents under Section 34 of the Act. However, considering the gaps in the GHC Rules regarding the procedure of filing applications under Section 34 or 37 of the Act, the Court directed that this order be placed before the Chief Justice for framing rules in this regard.

ii. Maintainability of the appeals filed herein by the respondents under Section 37 as Cross-Appeals

Regarding the position of law on the scope of challenge to the arbitral award under Section 34 and the scope of appeal under Section 37 of the Act, the Court reiterated the narrow jurisdiction conferred on Courts under Section 34. Thus, when it came to the scope of an appeal under Section 37, the jurisdiction of the Appellate Court (‘Single Judge’) in examining an order setting aside or refusing to set aside an award was even more circumscribed.

Accordingly, the Court held that it had to examine the validity of the award, confining itself within the limits of the powers prescribed in the statute. Thus, there was no reason to delve into the issue of the maintainability of appeals filed by the respondents under Section 37 as cross-appeals, confining the challenge to the issues decided against them. The Court found it fit and proper to deal with all grounds of challenge to the arbitral award raised under Section 34 within the scope of the appeals under Section 37. All appeals, thus, were heard together and decided by this common judgment.

iii. Section 29A — Termination of Mandate of the Arbitral Tribunal

While placing reliance on TATA Sons (P) Ltd. v. Siva Industries & Holdings Ltd., (2023) 5 SCC 421, the Court stated that the requirement of making an application seeking an extension of the mandate of the Arbitrator when the period of 12 months came to an end had been eliminated via the amendments brought in Section 29A (1) with effect from 30-08-2019 in case of international commercial arbitrations. Resultantly there was no need to move any application to the Court seeking an extension of the mandate of the Arbitral Tribunal beyond the lapse of the 12-month period in the instant case.

Further, the Court stated that the filing of an extension application for the Arbitrator’s mandate as per Section 29A (4) or (5) had no link with the pendency of the arbitration proceedings. The expression “the mandate of the Arbitrator shall terminate” under Sub-section (4) of Section 29A had been interpreted succinctly by the Apex Court in the case of Rohan Builders (India) (P) Ltd. v. Berger Paints India Ltd., 2024 SCC OnLine SC 2494, wherein it was held that the word ‘terminate’ in the contextual form does not reflect termination as if the proceedings have come to a legal and final end and cannot continue even on filing of an application for extension of time.

By placing a joint reliance on TATA Sons (supra) and Rohan Builders (supra), the Court stated that even when no application filed by any of the parties seeking extension the Arbitral Tribunal’s mandate was pending as of the date of amendment to Section 29A, the Arbitral Tribunal constituted with the consent of the parties, in the instant case, could not be said to have become functus officio. In terms of the amended provisions of Section 29A, the Arbitral Tribunal must simply dispose of the proceedings as expeditiously as possible. In the post-amendment regime, the fixation of the timeline for making the award in the case of international commercial arbitration, thus, remains within the domain of the Arbitrator and is outside the purview of judicial intervention.

Also referring to Section 32 of the Act, which provides how the arbitral proceedings shall be terminated by an Arbitral Tribunal, the Court noted that no clause stated that the arbitration proceedings shall stand terminated with the termination of the mandate of the Arbitrator as prescribed in Section 29A (4).

Thus, the Court held that the fact that no extension application was filed by the parties before the amendment or no such application was pending as of the effective date was irrelevant.

B. Main

i. Fee and Costs being Exorbitant: Whether Jurisdictional Error?

The Court relied on ONGC Petro Additions Ltd. v. Ferns Construction Co. Inc. 2020 SCC OnLine Del 2582, wherein the Supreme Court upheld the principle of party autonomy while fixing the Arbitrator’s fee and has observed that if while fixing costs or deposits, the Arbitral Tribunal makes any finding relating to Arbitrator(s) fees (in the absence of an agreement), it cannot be enforced in favour of the Arbitrator(s). Any disagreeing party can approach the Court to review the fees demanded by the Arbitrator(s). The Court also issued directives governing fees of the Arbitrator(s) in ad-hoc arbitrations emphasizing a consensus between the parties and the Arbitrators/Tribunals, which should be arrived at the preliminary stage in the matter of determination of the fee of the Arbitrators’/Tribunal. The Court also held that resolution of the fee payable to the Arbitral Tribunal by mutual agreement during the preliminary hearing is necessary.

Thereafter, the Court perused the facts and circumstances and noted that in the preliminary meetings of the first Arbitral Tribunal undisputedly agreed to pay Rs 5.5 Lakhs each. The second Tribunal reiterated the same fee. However, the third Tribunal stated that the fee and expenses had to be paid in Singapore Dollars (‘SGD’) with an advance deposit for expenses by each party. The respondents objected that they would not be able to pay the advance payment of SGD 50,000 per Arbitrator. Despite objections, the Presiding Arbitrator passed an order holding that the appellant shall have to pay the full amount of deposit required to pursue its claim to the Tribunal as respondents did not intend to make payment of their share of the Arbitrators’ fee. It was further stated that there should be no counterclaims as the respondents were not ready to deposit the Arbitrators’ fee, and if they wished to raise any counterclaim, they would have to pay the required deposits.

The Court further noted that the respondents were afforded many extensions in time to file their evidence without any conditions attached by the previous Tribunals, but they failed to do so. Noting this, the Court rejected the contention that the respondents needed a time extension to file their evidence.

Upon perusal of the transcript of the proceedings, the Court stated that it was evident that there was no agreement or consent of the respondents on the fee fixed by the Arbitral Tribunal. The Court further noted that in the decision of the Tribunal regarding the fee, the Presiding Arbitrator held that the fee of the Tribunal was aligned with that of an international Arbitrator under the Singapore International Arbitration Centre (‘SIAC’) or International Chamber of Commerce (‘ICC’) rules and could not be described as ‘herculean’. However, the Court also noted that respondent 1 did not avail the remedy of approaching the Court for fixation of a reasonable fee of the Arbitral Tribunal nor moved any application seeking termination of mandate under Section 14.

The Court opined that the reconstituted Arbitral Tribunal could not have revised their fee unilaterally, which was much more than the earlier fees fixed by the previous Tribunal, without the consent of the parties. As clarified by the Supreme Court in ONGC (supra), the Court reiterated that there is no enabling provision under the Act empowering the Arbitrator to unilaterally fix its fee and enforce its order regarding the fixation of the fee. Thus, the Court held that the order passed by the Arbitral Tribunal compelling the respondents to pay the fee determined by it was contrary to the cardinal principle of party autonomy.

ii. Scope of Section 34/37: Principle of Interference in the Award on the ground being in conflict with the Public Policy of India

In this regard, the Court referred to the landmark decisions in Associate Builders v. DDA (2015) 3 SCC 49, Ssangyong Engg. & Construction Co. Ltd. v. NHAI (2019) 15 SCC 131, and Renusagar Power Co. Ltd. v. General Electric Co. 1994 Supp (1) SCC 644, and stated the grounds of challenge put forth by the respondents would have to be decided considering the precedent that the term ‘public policy’ encompassed a narrow scope.

a. Grounds of Challenge to the Arbitral Award

1. Non-Disclosure under Section 12(1)

At the outset, the Court stated that Section 12 was amended to identify the circumstances “which give rise to justifiable doubts about the independence and impartiality of the Arbitrator”. The Fifth Schedule of the Act enumerates the grounds which may give rise to justifiable doubts of this nature, whereas the Seventh Schedule mentions those circumstances which would attract the provisions of Section 12 (5) of the Act and nullify any prior agreement to the contrary. The Court further stated that undisputedly, an award rendered in an International Commercial Arbitration was also subjected to the same test for setting it aside under Section 34 of the Act.

Thereafter, the Court opined that the fact that the Co-Arbitrator was a partner in Rajah Tann LLP (a law firm) wherein the son of the third Presiding Arbitrator worked as a Deputy Head of the Department of International Practices, could not be brought under the umbrella of the circumstance enumerated in Item 28 of the Fifth Schedule, i.e., a circumstance of relationship between one Arbitrator with another Arbitrator. The Court stated that in the instant case, Rajah Tann was not representing any of the parties in the arbitration proceedings. A close family member of the third Presiding Arbitrator, working in the law firm wherein a Co-Arbitrator was a partner, could not be a circumstance creating a conflict of interests to be brought within the scope of Item 28. Any such effort by us would go beyond the principle of fair construction of the words used in the Fifth Schedule and would tend to enlarge its scope unduly.

Thus, the Court held that the said category stated in the Fifth Schedule was not attracted to the facts of the present case, creating any justifiable doubts as to the independence or impartiality of the Arbitrator. Any such attempt of the Court to enlarge the scope of Item 28 of the Fifth Schedule to bring in the circumstance placed herein under the umbrella of the said enumerated grounds would amount to making an exception skipping the statutory route carefully devised by the Parliament, leading to uncertainty in the arbitration process.

Accordingly, the Court held that the ground of mandatory non-disclosure under Section 12(1) raised in the proceeding under Section 34 was nothing but an afterthought and could not be sustained to attach invalidity to the award.

2. Plea of violation of Principles of Natural Justice and Bias – Violation of Section 18 of the Act

To adjudicate on this issue, the Court delved into the following circumstances highlighted by the respondents:

  • Non-adjudication of Counter claims of the respondents and denial of opportunity to lead evidence

The Court noted that the respondents were given seven opportunities to file their evidence, sought several adjournments and did not file an application under Section 14 of the Act regarding the alleged exorbitant fees. The Court stated that the non-participation of the respondents in the arbitral proceedings since its inception, even before the second Tribunal, was proved from the record. Thus, the Court rejected the plea that the award suffered a violation of principles of natural justice on account of the refusal of sufficient opportunity for the respondents to lead their evidence.

Regarding non-adjudication of counterclaims due to non-payment of fee, the Court stated that upon perusal of Section 38(2) along with the 1st and 2nd provisos as well as the proviso to Section 38(1), it was clear that since claim and counterclaim were separate proceedings, separate fee could be contemplated. In case one party fails to pay his share of the deposit in respect of claim and counterclaim, the other party may deposit in respect of claim and counterclaim. Simultaneously, it is also open for the Arbitral Tribunal to suspend or terminate the proceedings in respect of such claim or counterclaim in case the other party does not pay its share in respect of the claim or counterclaim.

Stating the aforesaid, the Court noted that in the present case, the appellant paid the fee for his claims, but the respondents did not, claiming it to be exorbitant thus, the respondents lost the right to get their counterclaims adjudicated by the Tribunal. The Court stated that in case of any dispute about the quantum of the fee, recourse to the appropriate legal remedy was required to be taken. Thus, the award could not be said to be suffering a violation of Section 18 of the Act because the Arbitral Tribunal had suspended the proceedings of the counterclaims for non-deposit of the Tribunal’s fee by the respondents.The order passed by the Tribunal in that regard did not amount to coercion or lead to a real likelihood of bias. Thus, the Court held that this contention was too far-fetched and unacceptable.

Accordingly, the Court held that the challenge to the arbitral award on the ground of bias and violation of principles of natural justice for non-adjudication of the counterclaim did not fall within the parameters of judicial review when it comes to the award rendered in an International Commercial Arbitration within the scope of Section 34(2)(b)(ii).

  • Unilateral fixation of the fee agreeable to the claimant only: Violation of Natural Justice and Bias

While placing reliance on ONGC (supra), the Court reiterated that unilateral fixation of fee by the Arbitrator cannot be enforced against the party who did not agree to such determination. The aggrieved party can still request the Court to review the fee demanded by the Arbitrators if it believes that the fees are exorbitant or unreasonable. The order passed by the Arbitrators unilaterally deciding the fee cannot be enforced in favour of the Arbitrators.

The Court stated that as per the record of proceedings, no circumstance(s) to press the plea of bias in the determination of fee by the Presiding Arbitrator of the third Arbitral Tribunal could be brought before the Court. The Court held that the Single Judge erred in holding that the Tribunal lost its mandate to adjudicate the claim of the claimants because of its act of unilaterally determining the Tribunal’s fee. The Court added that the respondents could have taken legal recourse under Section 14 of the Act, and they could still do so, but it could not have been demonstrated that the respondents were disadvantaged by fee revision. Furthermore, the rejection of the counterclaim was not pursued by the respondents by taking recourse to the remedy available in law, which had no bearing on the issue of fee determination.

Thus, the Court concluded that the act of the Arbitral Tribunal in unilateral fixation of fee/revision of fee would not make the award itself invalid, being opposed to the public policy of India, and this violation, in breach of party autonomy, could not be said to be such which would shock the conscience of the Court to hold the award, in its entirety, conflicting with the Public Policy of India. The question of the lack of jurisdiction of the Arbitrator in entering the merits of the claim did not arise at all.

The Court remarked that accepting the contention of the respondents that on the objections by the respondents, the Arbitrators have no option but to walk out of arbitration proceedings as they have lost jurisdiction to adjudicate, would set a dangerous precedent as it would give a baton to one party to frustrate the arbitration proceedings by mere disagreeing with the fee fixed by the Arbitrators without taking recourse to the legal remedy.

Lastly, the Court stated that the award of determination of claims of the claimants could be separated from the order of the Arbitrators for fixation of fee of the Arbitral Tribunal, which did not form part of the arbitral award, since, it cannot be enforced in favour of the Arbitrators given the law laid down in ONGC (supra) on the doctrine of prohibition of in rem suam decisioi, i.e., no one can be the judge of his own cause.

Holding the aforesaid, the Court conclusively held that the contentions regarding bias were not sufficient to hold that the Arbitral Tribunal had conducted the proceedings in breach of principles of natural justice.

C. Merits of the claims

a. Award of Rs 22.19 Crores with interest for misappropriation of funds of LLP

The Court noted that the Tribunal found that respondent 1 was guilty of misappropriating funds from the accounts of the LLP, which was a breach of his fiduciary duties, but respondent 2 was not found guilty.

Noting the aforesaid, the Court stated that these findings were based on evidence on record and could not be reappreciated within the scope of Section 34 of the Act, and there was no challenge to the same. The only ground of challenge to the merits of the award, as noted herein above, was the plea that the LLP, being an independent legal entity from that of its partners, the claims could not have been filed by the appellant on behalf of the LLP.

Regarding this contention, the Court stated that from a reading of Section 23 of the Limited Liability Partnership Act, 2008 (‘LLP Act’), and clauses of the LLP Agreement, it could be seen that mutual rights and duties of partners of the LLP were aligned in the LLP Agreement and for breach of obligations, one partner or LLP could sue the other. As per Section 27 of the LLP Act, the LLP was liable for the wrongful act or omission on the part of a partner in the course of business of the LLP or its authority. Section 26 further made it clear that any partner of the LLP, for its business, is an agent of the LLP. Thus, the Court stated that the parties who were partners of the LLP could sue each other for breach of obligations as any dispute between them shall be governed by the LLP agreement itself.

Accordingly, the Court held that there was no infirmity in the decision of the Arbitral Tribunal in holding that respondent 1 was liable to pay Rs 22.19 Crores to the LLP together with interest of 12% per anum by concluding that he owed a fiduciary duty to the partners of LLP and the LLP in the management of its funds. Furthermore, the Court upheld the findings that Clause 21 of the LLP agreement read with item 4 of the First Schedule and Section 23(4) of the LLP Act afforded the legal basis for the Tribunal to make an order as prayed for by the claimant on behalf of the LLP.

b. Award of damages to the tune of Rs 84 Crores for Loss of Profits

At the outset, the Court noted that Clause 34 of the LLP agreement outlined limitations of liabilities/ indemnification. Clause 34(A) restricts the liability of partners towards each other or to the LLP concerning any special, indirect, incidental consequential, or punitive damages, whereas Clause 34(B) restrains indemnification by one partner to another partner or LLP for any loss, claim, damage, liability or action, except to the extent resulting from its respective gross negligence or willful wrongdoing which cannot override Clause 34(A).

The Court agreed with the respondents’ contention that Clause 34(B) covered indemnification for actual losses on willful wrongdoing when a partner incurs third-party liability and not intra-partner disputes. In any case, the Court held that this clause could not be invoked to incur liability of damages for the loss of profits, especially barred in clause 34(A) of the LLP Agreement. Furthermore, the Court noted that Clause 21 of the LLP Agreement clarified that the partner’s liability shall be limited as provided in the LLP Act and as outlined in the LLP agreement. When the partners themselves provided a limitation on the liability against each other in the written agreement given to them, no partner could be held liable to the other partner or the LLP for the damages mentioned in Clause 34(A), which includes punitive damages or “lost profits”.

Thus, the Court upheld with the Single Judge and minority view of the Arbitral Tribunal that the Arbitral Tribunal had no power to award damages to the tune of Rs 84 Crores or any other sum by way of “loss of profits'”

c. Award of Costs and Expenses

At the outset, the Court noted that the appellant sought costs incurred in the pursuit of arbitral proceedings and other legal proceedings. The Tribunal concluded that respondent 1 intentionally engaged in conduct designed to prolong the arbitration to cause financial ruin to the claimant. Such conduct greatly enhanced the legal costs and expenses incurred by the claimant and the remaining respondents. Thus, the Tribunal concluded that respondent 1 shall bear the costs and expenses of the parties, the costs and expenses of their legal team and the respective counsels of the claimant, respondents no.3 and 4, and the arbitration proceedings, including the Arbitrators, on a full indemnity basis. However, the Single Judge set aside the award, holding that the costs awarded by the Tribunal were contrary to the provisions of Sections 31A of the Act. The Single Judge stated that the Tribunal gave expansive meaning to Explanation (v) of Section 31A(1) “any other expenses incurred in connection with the arbitral or court proceedings and the arbitral award” and construed it to widen the scope of Section 31A, which was impermissible.

Noting the aforesaid, the Court referred to Section 31A of the Act, which states that the Tribunal had the power to allow reasonable costs to be recovered from the losing party. The Court reiterated that the word “discretion” connotes necessarily an act of a judicial character and is used concerning discretion exercised judicially. Hence, the question was whether the exercise of discretion and award of costs by the Arbitrator, in the instant case, violates the “fundamental policy of Indian law” within the meaning of Section 34(2) (b)(ii) of the Act.

In this regard, the Court placed reliance on Ssangyong Engg. & Construction Co. Ltd. v. NHAI (2019) 15 SCC 131, wherein the Supreme Court cautioned that judicial interference with an arbitral award in international commercial arbitration on the plea of “contravention with the fundamental policy of Indian law” or “in conflict with the most basic notions of justice or morality” can be attributed only in very exceptional circumstances when the conscience of the Court is shocked by the infraction of fundamental notions or principles of justice.

Noting this, the Court this standard for the application of the most basic notions of justice” test was not satisfied on the ground that the Arbitrator had given expansive meaning to Section 31A by awarding costs of litigation drawn in higher courts, such as High Court or the Supreme Court. The Court stated that the discretion exercised by the Arbitrator to award costs of litigation to the successful party considering respondent 1’s conduct could not be said to be unreasonable within the meaning of Section 34(b)(ii) of the Act. Thus, the Court concurred with the Single Judge’s opinion to set aside the award of costs.

D. Doctrine of Severability: When claims are distinct

The Court concluded that apart from the arbitral award for damages of Rs 84 Crores towards ‘loss of profit’ passed in favour of the claimant, the award for all other claims of the claimant awarded by the Arbitral Tribunal cannot be interfered with.

Regarding the question as to whether the award passed in arbitral proceedings can be severed to save the valid part of the award while setting aside the invalid one, the Court relied on Gayatri Balasamy v. ISG Novasoft Technologies Ltd., 2025 SCC OnLine SC 986, wherein it was held that Section 34(2)(a)(iv) permits the Court to sever the non-arbitrable portions of an award from arbitrable ones. The authority to sever the ‘invalid’ portion of an arbitral award from the ‘valid’ portion while remaining within the narrow confines of Section 34 is inherent in the Court’s jurisdiction while setting aside an award. A contrary interpretation would not only be inconsistent with the statutory framework but may also result in valid determinations being unnecessarily nullified. However, a caveat was added that ‘valid’ and ‘invalid’ portions must not be interdependent or intrinsically intertwined. In this regard, the Court referred to several other judgments to reiterate that the doctrine of separability applied to arbitral awards.

Conclusion

In conclusion, the Court held that the award of the claim of Rs 22.19 Crores together with interest at 12% per annum, as upheld by it, was separable from the award of damages for ‘loss of profit’ of Rs 84 crores along with interest at 12% per annum, which had been held invalid.

With this, the Court upheld the arbitral award in part, for the following claims :

  1. Award in favour of the appellant and respondent 4, and order respondent 1 to pay the LLP Rs 22.19 Crores with interest at the rate awarded by the Arbitral Tribunal.
  2. Award of costs as imposed by the Arbitral Tribunal upon respondents 1 and 2 jointly and severally concerning the arbitration proceedings towards all the costs and expenses incurred by the claimant on a full indemnity basis.

Accordingly, the appeals under Section 37 of the Act filed by the appellant were partly allowed. The impugned judgment and order passed by the Single Judge in setting aside the arbitral award, in its entirety, on the grounds of jurisdictional error, was set aside. As a result, the execution petition filed by the appellant, which was disposed of by the Single Judge, was revived and directed to be listed before the appropriate bench.

[Manbhupinder Singh Atwal v. Neeraj Kumarpal Shah, R/First Appeal No. 2819 of 2024, decided on 13-06-2025]

*Judgment authored by: Chief Justice Sunita Agarwal


Advocates who appeared in this case:

For the appellants: Sr. Advocate Dr. S. Murlidhar, Pranav Vyas, Kartik Yadav, and Parth Contractor Sr. Advocate Saurabh N. Soparkar, Bhadrish S. Raju, Karan Shah, and Manya Anjaria Sr. Advocate Kapil Sibal, Masoom K. Shah, Manisha Singh, Jay Shah, Parth Thummar, and Dhruvin Dossani

For the defendants: Sr. Advocate Saurabh N. Soparkar, Bhadrish S. Raju, Karan Shah, and Manya Anjaria iSr. Advocate Kapil Sibal, Masoom K. Shah, Manisha Singh, Jay Shah, Parth Thummar, and Dhruvin DossaniSr. Advocate Dr. S. Murlidhar, Pranav Vyas, Kartik Yadav, and Parth Contractor

Must Watch

maintenance to second wife

bail in false pretext of marriage

right to procreate of convict

Criminology, Penology and Victimology book release

Join the discussion

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.