An Arbitration Clause Confined To Work Within A Specified City Cannot Be Extended By Conduct To Cover Work Done Elsewhere: Allahabad High Court

Introduction

In M/s Regenvo Mobile Private Limited v. M/s Siyogi Enterprises [Appeal Under Section 37 of Arbitration and Conciliation Act 1996 No. 75 of 2024, decided on 12 December 2025], the Allahabad High Court (Lucknow Bench) allowed an appeal under Section 37 of the Arbitration and Conciliation Act, 1996 (the "Act") and set aside an arbitral award as well as the order of the Commercial Court which had dismissed the challenge under Section 34 of the Act.

The High Court held that where an agreement expressly confined the engagement of an advertising agency to the city of Lucknow, the arbitration clause therein could only cover disputes arising from work done within Lucknow. The Sole Arbitrator's finding that the scope of the arbitration clause extended to disputes relating to work done across all districts of Uttar Pradesh – based merely on the parties' conduct of issuing and paying for work orders beyond Lucknow – was held to be a patent illegality, as it effectively modified