An ICC sole arbitrator in Singapore rendered an award in favor of Taisei in respect of a contract containing an arbitration clause and governed by Pakistani law. A.M. Construction Company (AMCC) applied to the Civil Judge at Lahore under Sect. 14 of the Arbitration Act 1940, seeking the issuance of a direction to the sole arbitrator to file  the award in the Court so that AMCC could challenge it on the grounds provided for in the Act. The Civil Judge granted the application. On appeal, the High Court affirmed the first instance decision, holding that the remedies provided for in the 1940 Act had not been repealed by the 2011 Act implementing the New York Convention in Pakistan, and that AMCC could rely thereon because the award was a domestic award. Referring to Pakistani and Indian case law, the Court explained that, by agreeing to a foreign seat (here, Singapore), the parties make an implied choice for the procedural law of the seat; however, the arbitration agreement, and its validity and scope, are substantive aspects governed by the proper law of the contract in which the arbitration agreement is contained (here, Pakistani law).