Delayed And Unworkable Arbitral Awards: Supreme Court's Intervention In Lancor Holdings Ltd v. Prem Kumar Menon

Introduction

The Supreme Court of India, in Lancor Holdings Limited v. Prem Kumar Menon & Ors [2025 INSC 1277; decided on 31 October 2025], has provided guidance on two fundamental aspects of arbitration law i.e. – (a) the effect of undue delay in pronouncing arbitral awards upon its validity; and (b) whether an unworkable award that fails to resolve the dispute between the parties is liable to be set aside on grounds of patent illegality and being opposed to the public policy of India under Section 34 of the Arbitration and Conciliation Act, 1996 (Act). The Supreme Court has also examined that if the award is liable to be set aside, what would be considered a fit case for exercising jurisdiction under Article 142 of the Constitution of India, 1950 as per the law laid down by the Constitution Bench in Gayatri Balasamy v. ISG Novasoft Technologies Limited¹.