Aeon Technologies Ltd, an Indian company, entered into a contract with Orion Machines Inc., a South Korean firm, for the supply of industrial equipment. The agreement contained an arbitration clause stating that disputes

The seat of Arbitration and governing law can be ascertained by referring to the Closest-Connection Test to Ascertain the Seat of Arbitration. In Dozco India Pvt Ltd. v. Doosan Infracore Co. Ltd 33(2011) , the Supreme Court held that if the parties fail to mention the seat of arbitration in the agreement, the presumption is that the parties have intended the laws of the venue of the arbitration to be the laws governing the arbitration as well unless an intention to the contrary has been shown. This is called the closest-connection test as the country/place that is most closely connected with the arbitral proceedings is used to determine the seat of arbitration. In the absence of an explicit agreement on the seat of arbitration, the closest-connection test is applied to determine the governing law. Since the contract specifies Singapore as the arbitration venue, there is a presumption that the parties intended for Singaporean law to govern the arbitration, unless there is clear evidence to the contrary. For Aeon Technologies Ltd. to establish Indian law as the governing law, it must demonstrate a strong contractual or factual basis indicating such intent. Otherwise, in line with standard arbitration principles, the laws of the arbitration venue (Singapore) will likely govern the proceedings. However, the substantive law of the contract may still be governed by Indian law if explicitly agreed upon in the contract.