In a dispute arising from a 2012 heavy-earth-moving-machinery contract for Mahanadi Coalfields' Kulda Open Cast Project that contained no arbitration clause, the parties later consented to a High Court-appointed sole arbitrator under Section 11(6) of the Arbitration and Conciliation Act, 1996.
After the Orissa High Court dismissed Mahanadi Coalfields' Section 34 challenge to the resulting award as non-maintainable before the District Judge, the Supreme Court held that the mere conduct of arbitral proceedings at a particular place does not, by itself, determine the juridical seat of arbitration absent an express designation or agreement, and that a State High Court's territorial jurisdiction under Section 34 extends to every Commercial Court or District Court within it unless the parties have fixed a seat or agreed otherwise. The Court set aside the Orissa High Court's order and restored the Section 34 petition to the District Judge, Sundargarh.