Delhi lacks territorial jurisdiction where customs seizure and proceedings occurred wholly outside Delhi.

The petitioners imported designer and decorative stainless-steel coils from China, which were seized at ICD Dadri, Uttar Pradesh, by the Commissioner of Customs, Noida.

The seizure was based on the authorities’ view that the goods were not classifiable under CTH 73269060 and required BIS certification under IS 6911.

The petitioners sought to set aside the seizure memos and obtain release of the goods, also challenging reliance on a Chartered Engineer’s certificate.

After the Court’s interim order, the Commissioner of Customs, Noida rejected provisional release.

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

Whether the Delhi High Court had territorial jurisdiction under Article 226 to hear a challenge to the seizure of goods at ICD Dadri and the related provisional-release decision of the Commissioner of Customs, Noida

Whether the location of CBIC or DRI headquarters in Delhi, or the petitioners’ reliance on CBIC policy and clearances of similar goods elsewhere, constituted a part of the cause of action in Delhi

Under Article 226, territorial jurisdiction depends on whether the cause of action, in whole or in part, arose within the High Court’s territory; a “minuscule” part may suffice, but cause of action must be understood in accordance with Alchemist Ltd. v. State Bank of Sikkim

As explained in Sterling Agro Industries Ltd. v. Union of India, the location of an appellate or revisional authority may form part of the cause of action, but it does not by itself compel the High Court to hear the matter; the court must also consider forum conveniens and the nature of the lis

The Court relied on M/s Meever India Private Limited v. Union of India & Ors. and distinguished Bakshish Ahmad v. Union of India & Ors., which concerned forum non conveniens rather than dismissal for lack of territorial jurisdiction

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

The issues concerning classification, the Chartered Engineer’s certificate, and compliance with CBIC policy were for the Commissioner of Customs, Noida to consider; the location of CBIC or DRI headquarters in Delhi did not make those matters part of the cause of action in Delhi.

Nor did the alleged clearance of similar goods at other ICDs establish a Delhi connection.

Applying Sterling Agro, the Court found that no part of the cause of action had arisen within its territorial jurisdiction and concluded that the case was one of lack of jurisdiction, rather than a discretionary refusal based on forum conveniens.

It considered Meever India directly applicable and distinguished Bakshish Ahmad on that basis.

It left the petitioners at liberty to pursue remedies before the appropriate forum and disposed of all pending applications.