R.BANUMATHI,J

1. Challenge in these appeals is the order of single Judge dismissing the applications [O.A.Nos.155 to 157 of 2011 and A.No.1002 of 2011] filed under Section 9 of Arbitration and Conciliation Act, 1996 holding that the substantive as well as the procedural law is outside the country [Singapore] and that the parties have impliedly excluded the jurisdiction of Part I of Arbitration and Conciliation Act, 1996. Though the appeals are of the year 2011, with the consent of both the counsel, main appeals itself were taken up for final disposal.

2. Factual background:- Appellant-Financial Software & Systems Private Limited was a distributor of ACIs Software products such as ‘BASE24’ and ‘PRM’ in India under an International Distribution Agreement [IDA] entered into on 29.04.1998 between the Appellant and the 2nd Respondent-ACI Worldwide (Asia) Private Limited. Subsequently during 2005, certain disputes and differences arose between the Appellant and the 2nd Respondent-ACI and Appellant filed suit in C.S.No.628 of 2008 to settle the disputes and differences. Several rounds of discussions and consultations took place between the Appellant and ACI which entering into