When the arbitration seat is unspecified, Section 11 jurisdiction lies with the court at the place most closely connected to the arbitration.

The petitioner and respondent No. 1 entered into a partnership deed in 2007 to constitute respondent No. 3 firm.

The firm later entered into two Joint Development Agreements (JDAs) with respondent No. 4.

The petitioner claimed that, despite his retirement under a 2018 reconstitution deed, he retained an interest in the firm and was subsequently re-inducted; respondents disputed that claim.

He invoked the arbitration clauses in the 2007 partnership deed and the JDAs, seeking appointment of an arbitrator under Sections 11(5) and 11(6) of the Arbitration and Conciliation Act, 1996.

A later Section 11 application by respondents before the Telangana High Court was dismissed because the petitioner had first approached the Karnataka High Court; the Telangana High Court reserved liberty to raise available grounds before the latter Court.

1. Whether the petitioner could invoke the arbitration clauses in the JDAs to refer his dispute concerning his alleged status and interests as a partner of respondent No. 3 firm.

2. Whether the Karnataka High Court had territorial jurisdiction to entertain the Section 11 petition arising from the arbitration clause in the partnership deed, which specified no seat, venue, or place of arbitration.

3. Whether the petitioner’s earlier filing before the Karnataka High Court under Section 11(11) determined that Court’s territorial jurisdiction.

Sections 2(1)(e)(i) and 11(5), 11(6), 11(6-A), 11(11), and 11(12) of the Arbitration and Conciliation Act, 1996 govern the competent court and appointment of arbitrators.

Under Section 11(12)(b), for a non-international arbitration, the relevant High Court is the High Court within whose local limits the principal civil court identified in Section 2(1)(e) is situated.

Section 11(11) addresses competing requests to different arbitral institutions and gives priority to the institution first approached; it does not itself determine territorial jurisdiction.

Where no arbitral seat is specified, the seat may be identified by applying the “closest and most intimate connection” test, with the parties’ intention—ascertained from the arbitration agreement and surrounding circumstances—being paramount (J&K Economic Reconstruction Agency v. Rash Builders India Pvt. Ltd., 2026 SCC OnLine SC 596, as quoted at para. 14).

Hotel Leelaventure Ltd. v. Appejay Oxford Bookstores Pvt. Ltd., ILR 2006 KAR 4449, was relied on for the distinction between the first-filed request under Section 11(11) and the separate question of the court’s jurisdiction.

The Court held that the petitioner’s dispute was essentially between persons claiming to be partners of respondent No. 3 and did not prima facie arise from the JDAs; the petitioner was also not a party or signatory to those agreements.

Accordingly, he could not rely on the JDA arbitration clauses for this dispute.

As to the partnership deed, it contained no designation of arbitral seat, venue, or place.

The firm was registered and conducted its business at Secunderabad, and the relevant dispute was closely connected to that location.

Applying the closest-and-most-intimate-connection test, the Court found that the competent principal civil court was at Secunderabad and, therefore, the competent High Court was the Telangana High Court.

The Telangana High Court’s dismissal of the later application under Section 11(11) did not decide that the Karnataka High Court had territorial jurisdiction; it had left the respondents free to raise their grounds before this Court.

Section 11(11) did not cure that jurisdictional defect.

The petition was dismissed.