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As per case facts, a developer and landowners were in dispute over a Joint Development Agreement. The arbitrator reserved the award but pronounced it nearly four years later, without explanation
...and without definitively resolving all key issues, particularly concerning compensation and the validity of sale deeds the developer executed in its favor. The High Court ultimately upheld the partial award, leading to the developer's appeal. The question arose whether undue and unexplained delay in delivering an arbitral award, resulting in an unworkable decision, vitiates the award as being against public policy or suffering from patent illegality. Finally, the Supreme Court held that while delay alone doesn't set aside an award, the extreme, unexplained delay coupled with an unworkable, rudderless award (which failed to resolve disputes after irreversibly altering the parties' positions) was against India's public policy and patently illegal. The Court exercised Article 142 powers to validate the disputed sale deeds on condition of the developer paying a round-sum penalty/compensation
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