“In the event of a dispute… the arbitration shall be conducted in accordance with the procedure provided in the Indian Arbitration Act of 1940 or any re-enactment or modification thereof. The arbitration shall be conducted in English. The seat of arbitration proceedings shall be London, UK”. Held: Factors considered were that we could not apply both laws because Indian and English law is different and it would be impractical. It was assumed that by choosing seat of arbitration to be in England and in English, parties must have intended to have English lex arbitri; however, internal procedural rules were held to be Indian.