The Delhi High Court in Khurana Educational Society v. Shashi Bala held that appellate interference under Section 37 is limited but justified where interim orders under Section 17 effectively grant final relief. It ruled that directing deposit of substantial usage charges despite disputed lease termination and liability amounted to premature adjudication. Interim measures must remain protective, not impose substantive financial obligations. Fact-intensive issues like mesne profits require full evidentiary determination, not interim fixation.
Delhi High Court clarifies limits of interim relief under Section 17 of the Arbitration and Conciliation Act, 1996
- Article
- Angad Baxi, Dheeraj Nair
- April 28, 2026
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Angad is a Partner in the Dispute Resolution practice at JSA, Advocates & Solicitors and a qualified Advocate-on-Record at the Supreme Court of India. He specialises in complex, high-stakes disputes, with a practice that combines courtroom advocacy with strategic risk management and crisis response.