An agreement between an Indian company and a Singapore party provides that their disputes shall be arbitrated with the SEAT in Singapore, with no express choice of the governing procedural regime. The arbitration is conducted in Singapore. In India, an application to set aside the resulting award under Part I of the Act:

Following Bharat Aluminium Co. v. Kaiser (BALCO), where the parties choose a FOREIGN seat, Part I of the Arbitration and Conciliation Act (including Section 34 set-aside) does NOT apply unless the parties have, in terms, agreed to Indian law governing the arbitration. The supervisory courts are those of the seat. A foreign award is enforced in India under Part II (New York Convention awards), subject to the narrow grounds the Act recognises. Part II enforcement is the only channel for such an award in India.