Although filing of awards in courts is no longer required under the 1996 Act, these cases may help determine the award under section 36. In Bijoy Das v UOI (1993) Arb LR 142, it was established that the jurisdiction lies with the court in the area where the cause of action wholly or in part arises, or where the opposite party actually or voluntarily resides, irrespective of whether the award was made at the instance of the petitioner or the other party. This view was also supported by the decision in Aligarh University v Vinay Engg (1994) 4 SCC 710.

Jurisdiction under section 20 CPC was also discussed, referring to Patil Roadways v Prasad Trading Co, AIR 1992 SC 1514. In cases where there is overlapping jurisdiction due to a corporation having its main or principal office at one place and a subordinate office at another, such as in FCI vs Avdomen Corporation (1999) 1 SCALE 503, the award can be filed in the place where the corporation has one of its places of business. For instance, if the agreement was executed in Delhi and the arbitration was in Bombay, the award could be filed in Bombay.

In Gour Chandra vs State of W. Bengal (2004) 2 Arb LR 454 (CAL), it was held that an arbitral award can be submitted for execution before a court that would ordinarily have jurisdiction to entertain a suit concerning the subject matter of arbitration.

Merely because the application under section 34 is filed in Jankham Bala Court in Gujarat by PB, Asha's application under section 9 cannot be said to lie in that Court alone by reason of Section 31(4) of the 1940 Act or Section 42 of the 1996 Act.

Regarding the foreign award, Pacific filed a section 34 application in the Gujarat Court, while Asha filed a section 9 application to restrain the Section 34 proceedings before the Bombay High Court, where Ashapura is registered.