Not every procedural order by an Arbitral Tribunal constitutes an interim award; only orders that finally adjudicate substantive disputes qualify for challenge under Section 34 of the Arbitration and Conciliation Act.

JUDGMENT :

HARISH VAIDYANATHAN SHANKAR, J.

1. With the consent of the parties, all the aforesaid Petitions were taken up together for hearing. Since they arise out of the same Impugned Order and involve substantially similar grounds and issues, this Court proceeds to adjudicate them by way of the present consolidated judgment.

2. These Petitions have been filed under Section 34 of the Arbitration and Conciliation Act, 1996 , Act assailing theOrders dated 25.07.2025, 22.09.2025 and 09.10.2025 , Impugned Orders passed by the Learned Sole Arbitrator, in arbitral proceedings titled “M/S Regency Jewellers and twenty-five others (Batch-A &B)” and “Asian Hotels (North) Ltd. AND Asian Hotels (North) Ltd (Batch-C) and Madonna’s”.

3. All the Petitions, namely, O.M.P. (COMM) 449/2025, O.M.P. (COMM) 460/2025 and O.M.P. (COMM) 475/2025, present Petitions, arise out of the same arbitral proceedings and challenge the same Impugned Orders. The Petitioners in the present Petitions, namely, H.S. Nag and Ors., Ajay Kumar Rastogi and Late Meena Rastogi through LRs, Petitioners respectively, belong to the same Batch of claimants, i.e., Batch B, before the Arbitral Tribunal.

4. It is common ground that all the Petitioners had initially sought identical reliefs in their respective Statement of Claims, SOC and had thereafter moved applications seeking identical amendments to their prayer clause of the SOCs.

5. The said applications for amendment, as well as subsequent review applications, having been disallowed by way of common orders, which are the Impugned Orders herein, the present Petitions were connected and taken up together for consideration.

BRIEF FACTS:

6. Shorn of unnecessary details, the facts leading to the present Petitions are as follows:

(a) The present Petitions arise out of an arbitral proceeding between 25 Claimants, including the Petitioners, and Asian Hotels (North) Ltd, Respondent, pending adjudication of the dispute inter se the parties.

(b) Upon filing of the SOC, the claimants were grouped into different batches based on the nature of relief sought. Initially, the Claimants were divided into two batches, namely, Batch-A and Batch-B, with Claimants within each batch seeking identical reliefs.

(c) At the commencement of the proceedings, Claimant Nos. 1 to 22 (Batch-A) were represented by one set of counsel, whereas Claimant Nos. 23 to 26 (Batch-B) were represented by a separate set of counsel.

(d) Subsequently, Claimant Nos. 23 to 25 also engaged counsel appearing for Batch-A. Over time, the composition of the batches crystallised such that Batch-A comprised Claimant Nos. 1 to 22, Batch-B comprised Claimant Nos. 23 to 25, and Batch- C comprised Claimant No. 26. One Claimant from Batch-A later withdrew from the proceedings upon settlement, leaving a total of 25 claimants before the learned Arbitrator.

(e) The present Petitioners constitute Batch-B and comprise Claimant No. 23 (Late Meena Rastogi through LRs), Claimant No. 24 (Ajay Kumar Rastogi), and Claimant No. 25 (H.S. Nag & Ors.).

(f) During the course of the arbitral proceedings, claimants from both batches, i.e., Batch-A and Batch-B, filed applications seeking amendment of their respective SOC, with respect to the reliefs prayed therein.

(g) On 25.07.2025, when the said applications were taken up for consideration, learned counsel appearing for Batch-B stated before the Arbitral Tribunal that the claimants of Batch-B did not wish to press their application for amendment and intended to prosecute their cl