Supreme court in the case of Imax Corporation v. M/s E-City Entertainment (I) Pvt. Ltd. [Civil Appeal No.3885 of 2017], while addressing the issue as to whether the seat of arbitration itself is a decisive factor to exclude Part-I of the Arbitration and Conciliation Act, 1996, it was held that “the relationship between the seat of arbitration and the law governing arbitration is an integral one.”
It was held that “the place of arbitration determines the law that will apply to the
arbitration and related matters like challenges to the award etc.” and “if in pursuance
of the arbitration agreement, the arbitration took place outside India, there is a clear
exclusion of Part-I of the Arbitration Act.”

[On 10th March, 2017]