ISSUE:
Whether Indian courts had jurisdiction over issues from international arbitration agreements involving parties who had completed numerous contracts, some before and some after the landmark decision in Bharat Aluminium Co. v. Kaiser Aluminium Technical Services Inc. (BALCO)?
Whether the language and circumstances of the arbitration agreement impliedly precluded Indian courts from exercising jurisdiction, specifically whether London was designated as the arbitral seat?
RULE:
The decision in this case was primarily based on the interpretation of the arbitration agreement and the applicability of Indian arbitration law. The court reviewed the concepts of "express or implied exclusion" of Part I of the Arbitration and Conciliation Act, 1996, as well as the notion of "presumed intention" and the significance of attaining a "fair result."