High Court may refuse discretionary jurisdiction under forum conveniens despite a partial local cause of action.

The petitioner filed a writ petition seeking various reliefs, including a Writ of Prohibition to restrain the Ministry of Home Affairs, Delhi Police, and Ministry of Defence from associating with the "Karate India Organisation" (Respondent private company) during pending criminal investigations

Additionally, the petitioner sought a Writ of Mandamus for the Ministry of Corporate Affairs to complete an inquiry into the company’s Section 8 license and for Delhi Police to ensure a fair investigation into FIR No. 259/2025 regarding fraudulent sports quota forms

The court noted that the petitioner had previously approached the Kerala High Court in W.P.(C) 1344/2025 seeking similar reliefs regarding the recognition and functioning of Karate sports bodies

1. Whether the Delhi High Court should exercise its discretionary jurisdiction when a similar, larger controversy is already pending before the Kerala High Court

2. Whether the pendency of a criminal complaint in Delhi is a sufficient factor to invoke the jurisdiction of the Delhi High Court under the doctrine of forum conveniens

The court applied the doctrine of forum conveniens, which permits a court to refuse to exercise its discretionary jurisdiction if another forum is more appropriate to decide the matter.

It relied on the Supreme Court precedent in Kusum Ingots & Alloys Ltd. v. Union of India and Anr. (2004) 6 SCC 254, which held that even if a small part of the cause of action arises within a High Court's territorial jurisdiction, the court is not compelled to decide the matter on its merits and may refuse to exercise jurisdiction in favor of a more appropriate forum

The court found that the "essential, material and integral cause of action" arose outside its territorial jurisdiction

It observed that the Kerala High Court was already seized of the broader controversy and was fully empowered to address the petitioner’s specific grievances

The court reasoned that the mere existence of a pending complaint against the Karate India Organisation in Delhi was not a determinative factor that compelled the Delhi High Court to hear the case

Applying the principles from Kusum Ingots, the court determined that it would be inappropriate to exercise its discretionary jurisdiction when the matter could be more effectively resolved in the jurisdictional High Court where the primary controversy was already under consideration

It granted the petitioner liberty to approach the jurisdictional High Court (the Kerala High Court) to seek the desired reliefs. The court further clarified that all rights and contentions of the involved parties remained open