High Court may grant limited interim relief while declining to exercise jurisdiction based on forum conveniens.

Vedanta was the successful bidder for the Radhikapur (West) Coal Mine in Odisha under the Coal Mines (Special Provisions) Act, 2015

A Coal Mine Development and Production Agreement (CMDPA) was executed in New Delhi on 11.01.2021

Following missed milestones, the Nominated Authority issued a third Show Cause Notice (SCN-III) on 15.12.2025 proposing the termination of the CMDPA

Vedanta challenged SCN-III before the Special Tribunal at Talcher, Odisha, which admitted the case but did not grant ex-parte interim relief

Vedanta then filed a writ petition before the Delhi High Court challenging the Tribunal's procedural orders.

The Single Judge held that the Delhi High Court lacked territorial jurisdiction because the mine and the Tribunal were in Odisha, but granted a status quo order against precipitative action until the Tribunal adjudicated the stay application

Both Vedanta (regarding jurisdiction) and the Nominated Authority (regarding the interim relief) appealed

1. Whether the Delhi High Court has territorial jurisdiction to entertain a writ petition challenging orders of a Tribunal located in Odisha, solely because the authority that issued the underlying show cause notice is located in Delhi

2. Whether a High Court can grant interim measures while refusing to entertain a writ petition on the grounds of forum non conveniens or lack of territorial jurisdiction

The court applied the doctrine of forum conveniens, establishing that even if a minuscule part of the cause of action arises within a jurisdiction, the court must determine if it constitutes a material, essential, or integral part of the cause of action as per Alchemist Ltd. v. State Bank of Sikkim

It relied on Sterling Agro Industries Ltd v. Union of India, which held that the location of an authority alone does not automatically confer jurisdiction if the lis is elsewhere

Furthermore, it applied the principle from L. Chandra Kumar v. Union of India that Tribunal decisions are subject to the scrutiny of the High Court within whose jurisdiction the Tribunal falls

Finally, it noted that a show cause notice is not a final order and does not usually create a cause of action for a writ until a final decision is rendered, per Okinawa Autotech International Pvt. Ltd. v. Union of India

The Court rejected Vedanta’s argument that SCN-III issued from Delhi conferred jurisdiction, reasoning that the writ specifically challenged the Tribunal's orders in Odisha, not the SCN-III itself

Since the Tribunal and the mine are in Odisha, the "material, essential, and dominant" cause of action did not arise in Delhi

The court distinguished Chinteshwar Steel Pvt. Ltd. because SCN-III was merely a notice, not a final order or an appellate decision that would allow a choice of forum

Regarding the Nominated Authority's appeal, the Court held that despite the lack of jurisdiction, the Single Judge was justified in granting limited interim protection to maintain the status quo. This was necessary to ensure the proceedings before the Tribunal did not become infructuous and was consistent with previous interim protections granted to the parties

It held that the Delhi High Court is not the appropriate forum as the dominant cause of action is in Odisha

However, it upheld the Single Judge's direction to maintain status quo qua any precipitative action until the stay application is adjudicated by the Special Tribunal, Talcher, as it was a limited and necessary measure to protect the interests of both parties

No order as to costs was made