The position of the law before the present judgment was also clearly in favour of party autonomy. 25 One of the first cases before the Supreme Court challenging the right of parties to choose a foreign-seated arbitration arose in Atlas Export Industries v. Kotak & Co. 26 In the said case, even though an Indian company had entered into a contract with a company incorporated in Hong Kong, the goods were to be supplied through an Indian company, namely, Kotak & Co. in Mumbai. As per the arbitration agreement contained in the contract, the arbitration was to take place in London in accordance with arbitration rules of Grain and Feed Trade Association (GAFTA). Dispute arose between the parties and a foreign award was delivered. The respondent moved an application under the provisions of the Foreign Awards (Recognition and Enforcement) Act, 1961 27 before the High Court seeking enforcement of the award.