Delhi High Court declines jurisdiction when primary cause of action arises elsewhere, affirming *forum non conveniens*.

The petitioner, Rajasthan Table Tennis Association, filed a writ petition seeking to quash an order dated January 28, 2026, passed by the Executive Committee of Respondent No. 1 and ratified in its AGM, which accorded recognition to "RTTA-1," a faction led by Respondent Nos. 2 and 3

The dispute originated from elections held on February 11, 2023, for the Rajasthan State Table Tennis Association (RSTTA), following which Respondent Nos. 2 and 3 were allegedly elected as office bearers

This led to the formation of two factions, RTTA-1 (led by Respondent Nos. 2 and 3) and RTTA-2 (led by Mr. Ranjit Malick and Mr. Mahendra Singh Umat)

The Registrar, Co-operative Society, rejected a complaint by Mr. Ranjit Malick on February 23, 2024

Respondent No. 1 appointed an Enquiry Committee which recommended recognition of RTTA-1 on July 5, 2024

An appeal against the Registrar's order was rejected by the Department of Sports and Youth Affairs

The Rajasthan High Court, in S.B. Civil Revision Petition No. 368 of 2024, remanded the issue of RSTTA election validity to the Department of Sports and Youth Affairs

A communication dated June 16, 2025, from the Rajasthan State Sports Council seeking dissolution and formation of an ad-hoc committee was stayed by the High Court of Rajasthan at Jaipur in S.B. Civil W.P. No. 9899/2025, filed by RTTA-1

The impugned order of recognition was passed on January 28, 2026

The petitioner became aware of this on February 5, 2026, and the minutes confirming ratification were circulated on February 9, 2026

The petitioner asserts that the Delhi High Court has jurisdiction because the effect of the impugned decision is pan-India and the decision was taken in Delhi

Whether the Delhi High Court has territorial jurisdiction to entertain the writ petition given that the underlying cause of action predominantly arose in Rajasthan, even though the impugned order was passed by an authority situated in Delhi

Whether the doctrine of *forum conveniens* should be invoked to decline jurisdiction in this case

The court applied the principle that the situs of the head office/registered office of the respondent does not solely determine territorial jurisdiction

It relied on precedents such as *The Indure Pvt. Ltd. v. Government of NCT of Delhi*, *Shristi Udaipur Hotels v. Housing and Urban Development Corp.*, *Riddhima Singh v. Central Board of Secondary Education*, *Smt. Manjira Devi Ayurveda Medical College and Hospital v. Uttarakhand University of Ayurveda and Ors.*, and *Michael Builders and Developers Pvt. Ltd. v. National Medical Commission and Ors.*, which emphasize that the "dominant facts" or "material, essential and integral" facts should guide jurisdictional determination

The court also invoked the doctrine of *forum conveniens*, as established in *Kusum Ingots Alloys Ltd. v. Union of India and Anr.*, which allows a court to refuse to exercise discretionary jurisdiction even if a small part of the cause of action arises within its territory

The court noted that the petitioner belongs to Rajasthan and seeks to represent that state, further highlighting that the entire factual narration from paragraphs 2-7 indicates that the material, essential, and integral cause of action arose within Rajasthan

While acknowledging that a part of the cause of action might arguably have arisen in Delhi because Respondent No. 1 is situated there and the impugned order was passed in Delhi, the court, citing *The Indure Pvt. Ltd.*, emphasized that such a connection should not be the sole reason to entertain a petition

The court reiterated that the location of the decision-making authority or the passing of an order in Delhi, which is a "constant factum," should not be considered a "dominant fact" or "material, essential and integral" to the dispute, especially when the underlying cause lies elsewhere

Relying on *Kusum Ingots Alloys Ltd.*, the court determined that even if a small part of the cause of action arises in Delhi, it is not a determinative factor, and the doctrine of *forum conveniens* allows the court to decline jurisdiction when the most convenient forum is elsewhere

It held that the material, essential, and integral cause of action arose within the State of Rajasthan and that the mere fact of the respondent's location or the order being passed in Delhi is insufficient to establish territorial jurisdiction

The petition was accordingly dismissed, with liberty granted to the petitioner to approach a court of competent jurisdiction

All rights and contentions of the parties were left open