Arbitration for Noida and Delhi NCR Businesses: Seat, Venue and Which Court Actually Has Jurisdiction

By Bhaskar Subramanian, Partner, S&S Co. Advocates & Solicitors and Adv. Anupam, Senior Associate, S&S Co. Advocates & Solicitors

Published 28 October 2026 · Law stated as on 26 October 2026 · Informational content, not legal advice: see our disclaimer

A Noida manufacturer and a Gurugram buyer sign a contract naming New Delhi as the 'venue' of arbitration, then fall into a dispute three years later and discover that one word in that clause decides whether their interim relief application and their eventual challenge to the award go to the Delhi High Court or to the commercial court sitting in Surajpur, Greater Noida.

The clause that decides everything else

Every other question addressed in this article, which court grants interim relief, which court hears a challenge to the award, which court appoints the arbitrator if the parties cannot agree, traces back to a single clause in the contract: the one naming the seat of arbitration. For a business based in Noida, Greater Noida or elsewhere in the National Capital Region, this clause typically chooses between Delhi and Gautam Buddh Nagar, and the choice is not a formality. It decides which High Court exercises supervisory control, and within Uttar Pradesh, whether that control runs through the Allahabad High Court directly or through the district-level commercial court at Surajpur with the High Court available only for appointment of arbitrators and appeals.

The trouble is that commercial contracts, including many drafted by businesses with substantial legal departments, routinely use words like 'venue' and 'place of arbitration' loosely, sometimes in the same clause as the word 'seat', without working through what each term is actually meant to achieve. This is not a drafting nicety that only matters in a dispute between large corporations. A small or mid-sized manufacturer in Noida with a single arbitration clause copied from a counterparty's standard terms can find itself fighting a jurisdictional battle in a second forum before it ever gets to argue the merits of its actual claim, losing months and legal fees to a question the contract should have settled on day one.

Seat versus venue: the law the Supreme Court has settled

The distinction between the seat and the venue of arbitration is now well established in Indian law, principally through two Supreme Court decisions. In Bharat Aluminium Co. v. Kaiser Aluminium Technical Services, commonly called BALCO, a Constitution Bench held in 2012 that the seat of arbitration is the equivalent of an exclusive jurisdiction clause, anchoring supervisory jurisdiction in the courts of that place, while a venue is merely the physical location, often chosen for the convenience of the parties, the tribunal or the arbitrators, and need not coincide with the seat at all. The Court read the definition of 'Court' in Section 2(1)(e) of the Arbitration and Conciliation Act, 1996 against this backdrop, holding that two categories of court can have jurisdiction: the court where the cause of action arises, under ordinary principles, and the court of the seat, which may have no other connection whatsoever to the underlying dispute.

The Supreme Court sharpened this further in BGS SGS Soma JV v. NHPC Ltd., reported at (2020) 4 SCC 234, where a contract's clause said arbitration proceedings 'shall be held' at New Delhi or Faridabad. The Court held that once parties designate a place for the conduct of arbitration proceedings without stating a contrary intention, that place becomes the juridical seat, and courts there get exclusive jurisdiction, excluding every other court that might otherwise have had a claim to hear the matter. The decision explicitly overruled an earlier ruling in Union of India v. Hardy Exploration that had tried to keep seat and venue analytically separate even where the contract gave no indication the parties meant anything different by the two words. The practical upshot for an NCR business is that a clause stating the arbitration 'shall be conducted at New Delhi,' without the word 'seat' appearing anywhere, will ordinarily still be read as fixing New Delhi as the seat, carrying exclusive jurisdiction with it, unless something else in the contract points the other way.

That 'something else' is where Gautam Buddh Nagar specific case law becomes directly useful. The Allahabad High Court has held that where a party has itself filed an application under Section 9 of the Arbitration Act before the commercial court at Gautam Buddh Nagar, that conduct counts as contrary indicia strong enough to prevent a venue named elsewhere, such as Delhi, from being elevated to the status of seat; a party cannot invoke the jurisdiction of one court through its own conduct and later argue that a different court altogether was always the exclusive seat. In a separate matter before the Delhi High Court decided in February 2026, the Court dismissed a Section 11 petition for want of territorial jurisdiction after finding that New Delhi was referred to in the contract only as one of several alternative locations for conducting proceedings, while the parties had unequivocally agreed, elsewhere in their arrangement, that the seat, and consequently the exclusive territorial jurisdiction, lay in Gautam Budh Nagar. These decisions together show Gautam Buddh Nagar functioning as a genuine, judicially recognised seat in its own right for NCR arbitrations, not merely as a fallback when Delhi is unavailable.

Why the Allahabad High Court is a different kind of forum from the Delhi High Court

A detail that trips up practitioners more used to Delhi-seated arbitrations is that the Delhi High Court and the Allahabad High Court do not occupy the same position in the court hierarchy for arbitration purposes, because of a structural difference that has nothing to do with arbitration law specifically. The Delhi High Court, along with the High Courts of Bombay, Calcutta and Madras, exercises what is called ordinary original civil jurisdiction, meaning it can function as a court of first instance for civil suits above a defined value, a power traceable to colonial-era charters and, for Delhi, to the statute that created the High Court itself, which gives it that jurisdiction for suits valued above two crore rupees. The Allahabad High Court has no equivalent power. Its jurisdiction over civil matters is appellate and supervisory, exercised through writ petitions, first and second appeals, and references, not through hearing suits at first instance.

This single structural fact changes where a UP-seated arbitration's day-to-day proceedings actually land. Section 2(1)(e) of the Arbitration Act defines 'Court,' for domestic arbitrations, as the principal civil court of original jurisdiction in a district, which includes the High Court only where that High Court itself exercises ordinary original civil jurisdiction. Because the Allahabad High Court does not, a Section 9 application for interim relief, and a Section 34 application to set aside an award, in a Gautam Buddh Nagar-seated arbitration go to the principal civil court of original jurisdiction in that district, which in practice, given the specified value and subject matter thresholds, is the commercial court at Surajpur, not the Allahabad High Court. The Delhi High Court decisions discussed above that recognise Gautam Buddh Nagar as the seat are themselves consistent with this: they point the parties to 'the competent court' in Gautam Buddh Nagar, which is the commercial court there, not to the Allahabad High Court.

Section 11, by contrast, does not follow this district-court pathway. The power to appoint an arbitrator where the parties cannot agree, under Section 11(4) to 11(6), sits with 'the High Court' for domestic arbitrations, meaning that a Section 11 application arising from a Gautam Buddh Nagar-seated arbitration goes to the Allahabad High Court, not to the Surajpur commercial court, since appointment of arbitrators was never a 'Court' function under Section 2(1)(e) in the first place; it is a separate power vested directly in the High Court by Section 11 itself, exercised currently by a judge of that Court or a person designated by its Chief Justice. The same split applies to Section 37 appeals from orders under Sections 9, 17 or 34, which go to the High Court exercising appellate jurisdiction over the seat court, meaning the Allahabad High Court for a Gautam Buddh Nagar-seated matter. A business should treat these as genuinely different addresses for genuinely different applications arising from the same underlying arbitration, rather than assuming one forum handles everything once it is seized of the dispute.

Interim relief under Section 9: getting there before the tribunal exists

Section 9 lets a party approach a court for interim measures, such as preserving property, securing the amount in dispute, or restraining a counterparty from disposing of assets, before arbitral proceedings begin, while they are pending, or even after an award is made but before it is enforced. For an NCR business, the practical question is almost always which court, given the seat versus venue question just discussed, and Gautam Buddh Nagar businesses have both filed and defended Section 9 applications before their own commercial court where the contract or conduct fixes the seat there.

A relevant illustration comes from Anju Jain v. WTC Noida Development Company, decided by the Delhi High Court in 2024 and reported as 2024 DHC 2849, which arose from an agreement connected to a Noida commercial development. The Court observed that the use of the word 'seat' is not compulsory in an arbitration agreement, and that courts must work out the parties' real intention from the contract as a whole, applying essentially the BALCO and BGS Soma framework. On the jurisdictional question specifically, the Court held that for matters not actually referred to arbitration, and for other disputes falling to be entertained by civil courts and other tribunals, courts in Noida, meaning Gautam Buddh Nagar, would have exclusive jurisdiction, while directing that the appointed arbitrator's proceedings be administered under the Delhi International Arbitration Centre's rules. The decision illustrates a pattern increasingly common in NCR disputes: an arbitration administered institutionally out of Delhi, with Delhi itself fixed as the seat, while civil disputes that fall outside the arbitration clause altogether remain anchored to Gautam Buddh Nagar under a jurisdiction clause expressly made subject to the arbitration agreement. Section 9 and Section 34 proceedings arising from the arbitration itself still follow the seat; in Anju Jain that means Delhi, not Gautam Buddh Nagar. A Gautam Buddh Nagar-seated arbitration keeps those applications at Gautam Buddh Nagar only where the contract or the parties' conduct fixes the seat there specifically, as in the separate Allahabad High Court and Delhi High Court decisions discussed above.

Businesses seeking Section 9 relief should also keep in mind that the courts have narrowed, though not closed off, the availability of this remedy once the arbitral tribunal itself is constituted. Section 9(3), inserted by the 2015 amendment, directs a court not to entertain a Section 9 application once the tribunal is constituted unless the court finds that the remedy under Section 17, which lets the tribunal itself grant interim measures, would not be efficacious. Courts applying this provision have treated it as a real filter rather than a formality, generally expecting a party to approach the tribunal under Section 17 once it exists and reserving Section 9 relief for situations where the tribunal genuinely cannot act in time or at all, such as before its constitution or where the relief sought is against a person who is not a party to the arbitration agreement and therefore outside the tribunal's reach altogether.

Appointing the arbitrator: Section 11 in practice today

The 2019 amendment to the Arbitration Act introduced a scheme under which arbitral institutions, graded by the Arbitration Council of India and designated by the Supreme Court for international commercial arbitration and by the High Courts for domestic arbitration, would take over the function of appointing arbitrators under Section 11, removing the courts from this process going forward. As matters stand today, the provisions that would operationalise this institutional mechanism have not displaced the pre-existing practice in any way that current High Court orders reflect; Section 11 applications continue to be filed directly with, and decided by, the High Court itself, exactly as under the position before the 2019 amendment. Businesses in Noida and Delhi NCR should plan on this basis, that a Section 11 application for a UP-seated arbitration goes to the Allahabad High Court and for a Delhi-seated arbitration to the Delhi High Court, rather than to any designated institution.

The scope of what a court examines at the Section 11 stage has been narrowed and clarified by the Supreme Court's three-judge bench ruling in SBI General Insurance Co. Ltd. v. Krish Spinning, which current High Court orders treat as having settled the question. The Court confined judicial scrutiny at this stage to essentially one question, whether an arbitration agreement exists between the parties, leaving everything else, including the merits of the dispute and most questions about whether particular claims fall within the scope of that agreement, to the arbitral tribunal itself under its power to rule on its own jurisdiction. A separate question the Court does examine is limitation: whether the Section 11 petition itself has been filed within time, and whether the underlying claims sought to be arbitrated are not already time-barred on their face.

On that limitation question, the Supreme Court's 2024 decision in Arif Azim Co. Ltd. v. Aptech Ltd., reported as 2024 INSC 155, filled a long-standing gap by holding that the Limitation Act, 1963 applies to Section 11(6) applications, and that in the absence of any period specifically prescribed, the residual three-year period under Article 137 of that Act governs. The Court set out a two-part test: first, whether the Section 11 petition itself was filed within three years, generally running from when the other side failed or refused to act on a notice invoking arbitration, and second, whether the claims the petitioner wants arbitrated are themselves 'ex facie dead,' meaning hopelessly time-barred on the face of the pleadings, regardless of whether the petition itself was timely. A court can refuse to appoint an arbitrator on either ground. The Court also used the occasion to call the three-year window 'unduly long' for this purpose and suggested Parliament consider legislating a shorter, dedicated limitation period for Section 11 applications specifically; no such amendment had been enacted as of this writing, so the three-year Article 137 position remains the governing rule for now.

Challenging the award: Section 34 and the limits of judicial review

Once an award is made, the losing party's recourse is a petition under Section 34 to set it aside, filed before the court with jurisdiction over the seat, within three months of receipt of the award, extendable by a further thirty days on sufficient cause but not beyond that combined period except in the narrow way the Supreme Court has read Section 5 of the Limitation Act into analogous provisions elsewhere in the Act. For a Gautam Buddh Nagar-seated arbitration, this means the Section 34 petition goes to the commercial court at Surajpur, consistent with the Section 2(1)(e) analysis set out earlier, and not to the Allahabad High Court, which becomes relevant only if the Section 34 order is itself appealed.

The grounds available under Section 34 remain deliberately narrow, and Indian courts have resisted repeated attempts to widen them into a general merits review. 'Patent illegality,' one of the grounds available for purely domestic awards, does not let a court re-examine how the tribunal read the contract or weighed the evidence; the Supreme Court has held squarely that this ground cannot be used to re-argue the tribunal's construction of the contract, confining it instead to illegality that goes to the root of the matter, such as an award that contradicts the substantive law of India, ignores the terms of the contract altogether, or rests on no evidence at all. A business expecting a Section 34 petition to function as a second round of arguing the facts should be disabused of that expectation early, since courts applying this standard dismiss a large share of such petitions precisely because they amount to little more than a request to re-decide the case on merits.

A related point that has generated its own line of authority concerns the seat itself as a Section 34 battleground. The Supreme Court has held, in a decision concerning Mahanadi Coalfields and GSCO Infrastructure, that the place where arbitral proceedings were actually conducted does not by itself decide the seat, restoring a Section 34 challenge that had been dismissed on the mistaken basis that physical conduct of hearings in one city settled the jurisdictional question. The Court has separately held, in a case concerning an exclusive jurisdiction clause read alongside a venue clause, that once the seat is fixed, courts of that seat have exclusive jurisdiction even where the contract separately names a different place as a 'venue' for other purposes, reinforcing that a Section 34 petitioner cannot shop around between the seat court and a court closer to where hearings happened to take place.

Appeals under Section 37: the same sixty-day trap as commercial suits

Orders under Sections 9, 17, 34 and certain other provisions of the Arbitration Act are appealable under Section 37, and where the underlying dispute is a commercial dispute of the specified value under the Commercial Courts Act, 2015, the limitation period for that appeal is the same sixty days fixed by Section 13(1A) of that Act, rather than the longer period that would otherwise apply to a civil appeal. The Supreme Court has confirmed that this sixty-day clock runs uniformly across such appeals, and that condonation of delay beyond it, while possible under Section 5 of the Limitation Act following the Court's 2021 correction of its own earlier, stricter ruling in N.V. International, is granted only exceptionally, for a short delay with a genuine, bona fide explanation, not as a matter of routine.

For an NCR business, the forum for a Section 37 appeal again tracks the seat: a Delhi-seated arbitration's Section 37 appeal goes to the Delhi High Court, which, because it exercises ordinary original civil jurisdiction, may have itself heard the Section 9 or Section 34 application being appealed, making the structure comparatively simple. A Gautam Buddh Nagar-seated arbitration's Section 37 appeal from an order of the Surajpur commercial court instead goes up to the Allahabad High Court, meaning the business moves from a district-level forum to the High Court for the first time at the appellate stage, a jump that Delhi-seated litigants generally do not have to make in the same way. The Supreme Court has also clarified, in the BGS Soma litigation itself, that not every order on a Section 34 petition is independently appealable under Section 37; an order that simply returns a Section 34 petition for want of territorial jurisdiction, without deciding anything about the award's validity, has been held not to qualify, so a party receiving such an order should refile at the correct forum rather than appeal the return order itself.

A separate limitation wrinkle specific to the interaction between Sections 33 and 34 deserves mention. Where a party has applied to the tribunal under Section 33 for correction or clarification of the award, the Supreme Court has held that the three-month clock for filing a Section 34 petition runs from the date the tribunal disposes of that Section 33 application, regardless of whether the tribunal grants or rejects what was asked for. A business that files a Section 33 application expecting it to simply pause the Section 34 clock indefinitely, or that assumes a rejection restarts the clock from the original award date, risks missing the Section 34 window altogether.

Institutional arbitration: a real option for UP-seated contracts

Ad hoc arbitration, where the parties appoint arbitrators themselves and manage the process without an administering institution, remains the default for most NCR commercial contracts, but it is no longer the only realistic choice, and businesses drafting fresh contracts should weigh institutional arbitration seriously rather than defaulting to ad hoc out of habit. The Delhi International Arbitration Centre, the institution attached to the Delhi High Court, has grown sharply in caseload, from roughly 2,857 cases and under 2,000 hearings in 2020 to over 10,000 cases and more than 15,000 hearings in 2024 on reported figures, a roughly two hundred and fifty per cent increase that reflects real uptake by commercial parties in the region rather than a marginal shift. The Centre revised its arbitration rules in 2023 and has since issued a code of ethics for arbitrators and practice directions covering deposits for interim-relief hearings and tribunal-ordered security, giving parties a reasonably mature procedural framework to opt into.

A separate statutory institution, originally created as the New Delhi International Arbitration Centre by a 2019 Act of Parliament and renamed the India International Arbitration Centre in 2022, exists alongside DIAC and should not be confused with it; the two are distinct bodies with different governance structures, and a contract naming one when the parties meant the other creates an avoidable dispute about which institution's rules actually govern. For a Gautam Buddh Nagar business contracting with a Delhi or Gurugram counterparty, naming an institution headquartered in Delhi does not by itself fix Delhi as the seat; the seat clause and the institution clause are legally separate choices, and a well-drafted contract should address both explicitly rather than assuming that choosing an institution answers the seat question by implication.

Choosing an institution carries real consequences for how disputes unfold in practice. An institutional framework fixes timelines for constituting the tribunal, provides a fee schedule that removes some of the uncertainty of ad hoc fee negotiations with arbitrators, and in many cases gives parties a ready-made emergency arbitrator mechanism for urgent relief before a tribunal is even constituted, something ad hoc arbitration in India generally cannot offer in the same structured way. Against this, ad hoc arbitration remains cheaper at the outset and gives parties complete control over who is appointed, which some businesses, particularly where the relationship and the likely disputes are modest in value, still prefer. There is no universally correct answer; the choice should follow from the size and complexity of the contracts a business typically enters into, not from habit or from simply copying a counterparty's preferred clause without considering whether it suits the business's own disputes.

Enforcing the award once it is final

An arbitral award that survives the Section 34 window, or that is upheld on a Section 37 appeal, is enforceable as if it were a decree of a civil court, under Section 36 of the Arbitration Act. The Supreme Court's decision in Sundaram Finance Limited v. Abdul Samad, reported in 2018, settled a question that had divided High Courts for years: whether an award-holder must first obtain a transfer of the decree from the court that had supervisory jurisdiction over the arbitration before executing it in a different court where the judgment debtor's assets are actually located. The Court held that no such transfer is required, reasoning that Section 36 makes the award enforceable under the Code of Civil Procedure in the same manner as a decree, and that Section 42 of the Arbitration Act, which otherwise confines all applications relating to an arbitration to a single court once that court is first approached, does not extend to execution proceedings at all, since execution is not itself an 'arbitral proceeding' within the meaning of that section.

For an NCR business that wins a Delhi-seated or Gautam Buddh Nagar-seated award against a counterparty whose actual assets, bank accounts or immovable property sit elsewhere entirely, in Mumbai, in another state, or anywhere else in the country, this means execution can be filed directly in the court nearest those assets, provided the ordinary territorial rules in Sections 38 and 39 of the Code of Civil Procedure for execution jurisdiction are satisfied. This is a meaningfully faster route than the earlier, divided practice under which some High Courts had insisted on a formal transfer decree from the seat court first, a step that could itself take months and gave a determined judgment debtor an additional opportunity to relocate or dissipate assets while the transfer application was pending.

Businesses should still expect execution to be the slowest part of the process in practical terms, whatever the formal jurisdictional position. Identifying the judgment debtor's attachable assets, particularly where the debtor is uncooperative, often requires independent inquiry that should begin well before the award is even final, using whatever information surfaced during the arbitration itself about the debtor's bank accounts, properties and business operations. A judgment debtor resisting execution retains the right to raise objections, including jurisdictional ones, at the execution stage itself, so a well-prepared execution petition, with the territorial basis for the chosen court's jurisdiction clearly pleaded and documented, saves real time compared to one that simply assumes jurisdiction is self-evident.

Drafting for Noida and NCR: what the clause should actually say

Given how much turns on a single clause, a business operating in or contracting with counterparties in Noida, Greater Noida or the wider NCR should treat its arbitration clause as one of the more consequential pieces of drafting in the entire contract, not boilerplate to be copied from the last agreement that happened to be on file. The clause should state expressly, using the word 'seat,' which city is the juridical seat of the arbitration, and should separately address venue only if the parties genuinely want hearings to be held somewhere other than the seat for convenience, making clear that this does not alter the seat. Leaving the choice to implication, through a bare reference to a 'place of arbitration' with no further elaboration, invites exactly the kind of contrary indicia dispute that has occupied the Allahabad and Delhi High Courts in the cases discussed above.

The clause should also name, separately from the seat, which institution if any will administer the arbitration, and should not assume that naming an institution based in one city fixes that city as the seat; where the parties genuinely want the two to align, for instance a Delhi seat administered by the Delhi International Arbitration Centre, the clause should say both things explicitly rather than relying on an inference that a court might later read differently. For a Gautam Buddh Nagar business that prefers, for cost or convenience reasons, to keep disputes anchored to its own commercial court rather than Delhi, naming Gautam Buddh Nagar as the seat directly, rather than leaving the question to arise only if a dispute happens to end up there by default, removes the single largest source of wasted litigation this article has described.

Finally, a business should think through, at the drafting stage rather than after a dispute has already arisen, how it expects to use Section 9 interim relief if things go wrong, since the availability of that relief, and the forum for seeking it, both depend on the seat choice made now. A business that regularly deals in goods or assets that could be moved, sold or dissipated quickly by a defaulting counterparty has a strong practical reason to fix the seat at whichever forum, Delhi or Gautam Buddh Nagar, it can realistically reach fastest and most familiarly when urgent relief is actually needed, rather than choosing a seat for reasons unconnected to how disputes with that particular kind of counterparty are likely to unfold.

Where the law is still settling

Two areas remain genuinely open rather than settled, and a business should not treat either as a safe assumption. The first is the eventual fate of the institutional appointment mechanism for Section 11 introduced by the 2019 amendment. Secondary commentary has for some years described the relevant provisions as awaiting notification, and current High Court practice, as reflected in the decisions discussed above, continues to treat Section 11 applications as matters for the High Court directly; whether and when this changes is a matter for government notification rather than judicial decision, and businesses should simply monitor the position rather than draft contracts on the assumption that an institutional mechanism will or will not displace direct High Court applications by any particular date.

The second is the precise reach of the 'contrary indicia' doctrine that let Gautam Buddh Nagar's commercial court assert jurisdiction over a Section 9 application despite Delhi being named in the contract as a venue. The doctrine, as applied so far, has turned heavily on a party's own conduct, specifically filing an application in a particular court, rather than on textual analysis of the contract alone. How far a court will go in reading conduct short of actually filing an application, such as correspondence referring to one city rather than another, as similarly decisive contrary indicia has not been tested with the same clarity, and businesses relying on conduct rather than clear contractual drafting to establish their preferred seat should understand that they are relying on a developing line of authority rather than a fixed rule.

Arbitration law in India has moved, over more than a decade of Supreme Court decisions, toward treating the seat as close to an exclusive jurisdiction clause, and the cases arising specifically out of Noida and the wider NCR show that principle being applied with real consequences for where a business actually has to show up to seek interim relief, challenge an award, or get an arbitrator appointed. None of this is exotic law reserved for large cross-border disputes; it governs the ordinary supply, construction and services contracts that NCR businesses sign every week.

The practical lesson is the same one that runs through this entire area: the time to think carefully about seat, venue and institution is when the contract is being drafted, not after a dispute has already produced a jurisdictional fight that delays the real argument on the merits. A business that gets the clause right at the outset, and that understands in advance which forum it will actually be dealing with if a dispute goes wrong, starts any future arbitration from a position of genuine readiness rather than one spent discovering, under time pressure, which court it should have gone to in the first place.

Frequently Asked Questions

References & Further Reading

The provisions, rulings and official documents below were relied on for this article, which states the law as on 26 October 2026. The position can change with amendments, rules and later decisions, so check the current text before acting on any of it.

1. Arbitration and Conciliation Act, 1996, Sections 2(1)(e), 9, 9(3), 11, 11(4)-(6), 17, 33, 34, 36, 37, 42
2. Arbitration and Conciliation (Amendment) Act, 2019
3. Limitation Act, 1963, Sections 5, Article 137
4. Commercial Courts Act, 2015, Section 13(1A)
5. Code of Civil Procedure, 1908, Sections 38, 39
6. Bharat Aluminium Co. v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552 (BALCO)
7. BGS SGS Soma JV v. NHPC Ltd., (2020) 4 SCC 234
8. Union of India v. Hardy Exploration and Production (India) Inc. (overruled by BGS SGS Soma)
9. Anju Jain v. WTC Noida Development Company, 2024 DHC 2849, Delhi High Court
10. Allahabad High Court, ruling on Section 9 application before Commercial Court, Gautam Buddh Nagar, as contrary indicia against a Delhi venue being elevated to seat
11. Delhi High Court, order dated February 2026, dismissing Section 11 petition for want of territorial jurisdiction, recognising Gautam Budh Nagar as seat
12. SBI General Insurance Co. Ltd. v. Krish Spinning, Supreme Court of India (three-judge bench, scope of Section 11(6) scrutiny)
13. Arif Azim Co. Ltd. v. Aptech Ltd., 2024 INSC 155
14. Mahanadi Coalfields Ltd. v. GSCO Infrastructure, Supreme Court of India (seat not decided by place where proceedings conducted)
15. Supreme Court of India, ruling that once the seat is fixed its courts have exclusive jurisdiction notwithstanding a separate venue clause
16. Supreme Court of India, ruling confining 'patent illegality' under Section 34 against re-argument of the tribunal's contractual construction
17. Sundaram Finance Limited v. Abdul Samad, Civil Appeal No. 1650 of 2018, Supreme Court of India
18. Supreme Court of India, three-judge bench ruling (2021, per Nariman, Gavai and Roy JJ) on condonation of delay under Section 13, Commercial Courts Act, overruling N.V. International v. State of Assam
19. Delhi International Arbitration Centre, revised Arbitration Rules (2023) and reported caseload figures
20. New Delhi International Arbitration Centre Act, 2019 (institution renamed India International Arbitration Centre, 2022)

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