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Law of the land where seat chosen shall apply in arbitration

The Supreme Court in EITZEN BULK A/S VS. ASHAPURA MINECHEM LTD. has reiterated that held that mere choosing of the juridical seat of Arbitration attracts the law applicable to such location and it would not be necessary to specify which law would apply to the Arbitration proceedings, since the law of the particular country would apply ipso jure. Apex Court bench comprising of Justices Fakkir Mohamed Ibrahim Kalifulla and S.A. Bobde also reiterated that where the parties choose a juridical seat of Arbitration outside India and provide that the law which governs Arbitration will be a law other than Indian law, Part I of the Arbitration and Conciliation Act, 1996 would not have any application and, therefore, the award debtor would not be entitled to challenge the award by raising objections under Section 34 before a Court in India. The court disposed of appeals arising out of Gujarat and Bombay High Courts, which had taken a contradictory view on the issue whether Part I of the Arbitrati...