The landmark judgment holding that in INTERNATIONAL commercial arbitration the 'SEAT' determines the courts with supervisory jurisdiction, and that Part I of the Act does not apply unless the parties choose an Indian seat, is:

Bharat Aluminium Co. v. Kaiser Aluminium (2012) is the watershed on the 'seat' doctrine: the supervisory jurisdiction over an arbitration belongs to the courts of the seat chosen by the parties, and Part I of the Arbitration Act (including Section 34 set-aside) does not apply to foreign-seated international commercial arbitrations. It overruled the earlier position that Part I applied unless impliedly excluded. The decision is prospective and has guided the court-versus-seat question ever since. ONGC v. Saw Pipes, a domestic award case, is relevant to public policy and patent illegality rather than to seat.