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Adhunik Steels Ltd vs Orissa Manganese And Minerals Pvt. Ltd on 10 July, 2007

20. There cannot be any dispute on the proposition that change in circumstances and undue hardship are grounds for discharge/modification of an interim order in terms of Order XXXIX Rule 4 of the CPC. Though there is no quarrel on the proposition that the power of substantive review does not vest in an Arbitral Tribunal, however, in the instant case, TDI was not seeking a review, but rather, a discharge/modification of the conditions prescribed in the said interim order, under Section 17 of the Act, in view of the change in circumstances. Thus, in the opinion of the Court, the Arbitral Tribunal was entitled to exercise the said option, having regard to the principles enshrined under Order XXXIX Rule 4 of the CPC. In fact, the Supreme Court has consistently held that while exercising powers under Section 9 of the Act, the Court is guided by the principles set out in Order XXXIX Rule 1 & 2 of the CPC.2 Similar views have also been expressed by the High Court of Bombay, holding that the Court or the Arbitral Tribunal, as the case may be, would be guided by principles contained in Order XXXVIII Rule 5 of the CPC. 3 Therefore, if, for considering the issue of vacation/ modification of an interim order, the Court or Arbitral Tribunal would be guided by the principles set out in Order XXXIX Rule 1 & 2 or Order XXXVIII Rule 5 of the CPC, for grant of relief, as the situation may require, the Court/ Tribunal can also be guided 2 Adhunik Steels Ltd. v. Orissa Manganese & Minerals Pvt. Ltd., AIR (2007) SC 2563.
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