High Court May Refuse Jurisdiction Under Forum Conveniens Despite Respondent's Presence if Cause of Action Arises Elsewhere

The petitioner, MDD Medical System India Pvt Ltd, filed a writ petition seeking directions against Respondent No. 1 (Hindustan Prefab Limited) for the release of purportedly undisputed outstanding dues amounting to Rs. 27,29,083/-

These dues arose from a 2018 work order for the installation of medical gas pipeline systems at the ESIC Hospital in Raipur, Chhattisgarh

Although the work was executed entirely in Chhattisgarh, the petitioner approached the Delhi High Court on the sole ground that the respondent company’s registered office is situated in New Delhi

1. Whether the mere situs of a respondent’s head office within the court's jurisdiction is a sufficient determinative factor to entertain a writ petition when the underlying cause of action arose elsewhere.

2. Whether the court should exercise its discretionary jurisdiction under the doctrine of forum conveniens when only a miniscule part of the cause of action arises within its territory.

The court relied on the Supreme Court precedent in Kusum Ingots Alloys Ltd. v. Union of India, which held that even if a small part of the cause of action arises within a High Court's jurisdiction, the court may refuse to exercise its discretionary jurisdiction by invoking the doctrine of forum conveniens

It further applied the principles from Indure Pvt. Ltd. v. Government of NCT of Delhi, which established that for a court to entertain a lis, the facts occurring within its jurisdiction must be "material, essential, and integral" to the dispute, rather than merely incidental or based solely on the location of a decision-making authority

The Court reasoned that the "situs" of the respondent in Delhi was not a determinative factor for territorial jurisdiction because the "dominant facts" and the "legal injury" occurred in Chhattisgarh, where the work was executed

The Court observed that in a national capital, many authorities have offices, but treating the location of a head office or the passing of an order as the sole basis for jurisdiction would erroneously turn the Delhi High Court into a "mini-pan-India Superior Court"

The Court found that the integral and substantial part of the cause of action remained in Chhattisgarh, making the connection to Delhi "minuscule" and "non-essential"

It held that the petitioner must approach the appropriate jurisdictional forum where the material part of the cause of action arose

The petition was disposed of with liberty to the petitioner to seek redressal before the competent court, leaving all rights and contentions open