Physical location of arbitral institution does not determine territorial jurisdiction for challenging an award.

The Appellant challenged an arbitral award dated 09.01.2018 by filing a petition under Section 34 of the Arbitration and Conciliation Act, 1996, before the District Court, Dwarka

The petition was instituted there on the grounds that the Respondent’s office is located in Janakpuri, which falls within the territorial jurisdiction of the Dwarka Court

Although the Respondent conceded to the court's jurisdiction, the District Court suo motu held it lacked territorial jurisdiction

The District Court reasoned that because the arbitral proceedings were conducted at the Delhi International Arbitration Centre (DIAC), jurisdiction lay with the court where the DIAC is physically located

Consequently, the District Court disposed of the petition, directing the Appellant to approach the competent court

1. Whether the physical location of an arbitral institution (DIAC) determines the territorial jurisdiction of a Court to entertain a Section 34 petition under the Arbitration and Conciliation Act, 1996

2. Whether a Section 34 petition can be validly instituted in a District Court based on the location of the Respondent’s office as per Section 20 of the Code of Civil Procedure, 1908

Section 13 of the Commercial Courts Act, 2015, regarding the maintainability of the appeal

Section 2(1)(e) and Section 42 of the Arbitration and Conciliation Act, 1996, to define the "Court" having jurisdiction

Section 20(a) of the Code of Civil Procedure, 1908, which allows a suit to be instituted where the defendant resides or carries on business

The precedent in Chacha Nehru Bal Chikitsalya, Delhi v. M/s Induction Corporate Solutions Pvt. Ltd., which settled that the physical location of an arbitral institution does not determine the jurisdiction for Section 34 petitions

The High Court set aside the District Court’s finding, observing that the trial court's conclusion lacked a legal basis

The Court reasoned that territorial jurisdiction in arbitration matters is governed by Section 42 and Section 2(1)(e) of the Act of 1996, read with the principles of Section 20 of the CPC

Since the Respondent maintained an office in Janakpuri, the District Court at Dwarka possessed competent jurisdiction under Section 20(a) of the CPC

The Court clarified that where the "seat" of arbitration is designated as "Delhi," the mere fact that proceedings were physically held at the DIAC does not restrict the filing of a Section 34 petition to the specific district court where the DIAC office is situated

The Court emphasized that this legal position is no longer res integra following the Division Bench ruling in Chacha Nehru Bal Chikitsalya

It held that the Section 34 petition was rightly instituted at the District Court, Dwarka, because the Respondent’s office was located within its jurisdiction and the seat of arbitration was Delhi

The Court directed the parties to appear before the District Court, Dwarka, on 13.04.2026, for the matter to be heard on its merits

All pending applications, including those for condonation of delay in filing and re-filing, were disposed of