Courts may decline writ jurisdiction under forum conveniens if the material cause of action arises elsewhere.

The Petitioner, a hospital situated in the State of Punjab, filed a writ petition seeking to set aside a communication dated 15.12.2025 issued by Respondent No. 2, the National Accreditation Board for Hospitals and Healthcare Providers (NABH).

The impugned communication informed the Petitioner that it had not been recommended for empanelment with the Ex-Servicemen Contributory Health Scheme (ECHS).

Although the Respondents are located in Delhi and the order was issued from Delhi, the Petitioner-hospital is located in Punjab, and the effects of the decision are felt therein.

Whether the Delhi High Court should exercise territorial jurisdiction over a matter where the underlying cause of action and the Petitioner are situated outside Delhi, solely because the decision-making authority is located within Delhi.

Whether the doctrine of forum conveniens permits the Court to refuse the exercise of discretionary jurisdiction despite a small part of the cause of action arising in Delhi.

The Court primarily applied the doctrine of forum conveniens and the principle of "dominant facts" or "material, essential and integral facts" to the lis.

The Court relied on the precedent of Indure Pvt. Ltd. v. Government of NCT of Delhi and Ors. (2026:DHC:1605), which established that the location of a pan-India authority in Delhi should not be the sole reason to entertain a writ petition if the legal injury occurs elsewhere.

The Court cited Kusum Ingots & Alloys Ltd. v. Union of India and Anr. (2004) 6 SCC 254, which held that a High Court may refuse to exercise discretionary jurisdiction even if a small part of the cause of action arises within its limits.

The Court reasoned that since the Petitioner-hospital is situated in Punjab, the entire cause of action effectively arose outside Delhi.

The Court observed that because Delhi is the national capital, many authorities with pan-India jurisdiction are headquartered there; however, the act of passing an order or holding a hearing in Delhi is often non-essential and non-integral to the actual dispute.

The Court emphasized that entertaining such petitions would erroneously transform the Delhi High Court into a "mini-pan-India Superior Court".

Applying the principles from Kusum Ingots, the Court determined that while the Respondents' location provided a technical nexus, it was not a determinative factor that compelled the Court to decide the matter on merits when the "dominant facts" were located in Punjab.

The petition was dismissed; however, the Court granted the Petitioner liberty to approach the appropriate jurisdictional High Court (Punjab).