Delhi lacks territorial jurisdiction where a customs seizure and the entire cause of action arise elsewhere.

The petitioners imported designer and decorative stainless-steel coils from China. Customs authorities seized the goods at ICD, Dadri, Uttar Pradesh, on the grounds that the goods were misclassified under CTH 73269060 and required BIS certification under IS 6911.

The petitioners sought to set aside the seizure memos, obtain release or provisional release of the goods, and prevent reliance on a Chartered Engineer’s certificate for classification.

The Commissioner of Customs, Noida, rejected provisional release following an interim order of the Court.

The respondents raised a preliminary objection that the Delhi High Court lacked territorial jurisdiction.

Whether the Delhi High Court had territorial jurisdiction to entertain a challenge to the seizure and continued detention of goods at ICD, Dadri, Uttar Pradesh.

Whether the location of the CBIC or DRI headquarters in Delhi, or the petitioners’ reliance on CBIC policy and the Chartered Engineer’s certificate, gave rise to a part of the cause of action in Delhi.

Under Article 226, territorial jurisdiction depends on whether the cause of action, or any part of it, arises within the Court’s territory. Even a minuscule part of the cause of action may suffice, but cause of action is assessed in light of the principles stated in Alchemist Ltd. v. State Bank of Sikkim (2007) 11 SCC 335.

The Full Bench decision in Sterling Agro Industries Ltd. v. Union of India (2011) 10 GSTR 20 holds that the location of an appellate or revisional authority does not, by itself, compel a High Court to hear a matter; the nature of the cause of action and forum conveniens must be considered in the factual context.

The Court also considered Ambica Industries v. CCE (2007) 213 ELT 323 and Union of India v. Adani Exports Ltd. (2002) 1 SCC 567 on forum conveniens, and distinguished Bakshish Ahmad v. Union of India, MANU/SC/0622/2026, as a case concerning forum non conveniens rather than lack of territorial jurisdiction.

The seizure, detention, and provisional-release proceedings were all connected to ICD, Dadri, and the Commissioner of Customs, Noida, outside Delhi’s territorial jurisdiction.

The petitioners’ arguments about CBIC policy, the Chartered Engineer’s certificate, and clearance of similar goods elsewhere went to the merits of the classification and seizure dispute, which were matters for the Commissioner of Customs, Noida; they did not establish that any part of the cause of action arose in Delhi. Nor did the location of the CBIC or DRI headquarters in Delhi confer jurisdiction.

Applying Sterling Agro, the Court concluded that the case involved neither a Delhi-based part of the cause of action nor a basis for Delhi to be the appropriate forum. It found M/s Meever India Private Limited v. Union of India & Ors., 2026:DHC:1574-DB, applicable.

It dismissed the petition and disposed of the pending applications, while preserving the petitioners’ liberty to pursue remedies before the appropriate forum.