Delhi High Court

High Courts may decline writ jurisdiction under forum conveniens if the material cause of action arises elsewhere.

M/S R.P. Transporters vs Hindustan Petroleum Corp. Ltd. & Ors.

Delhi High CourtJUDGMENT: April 06, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, M/S R.P. Transporters, filed a writ petition seeking to quash a termination order dated 30.03.2026 issued by Respondent No. 1 (HPCL), which cancelled a Letter of Acceptance (LoA) dated 05.09.2025

Source reference: para. 3

The underlying contract pertained to transportation services to be performed within the State of Punjab

Source reference: para. 5

The Petitioner invoked the jurisdiction of the Delhi High Court on the grounds that the LoA and the impugned termination order were issued from New Delhi

Source reference: para. 5

Furthermore, the Petitioner contended that the parties had mutually agreed via contract to the jurisdiction of the Delhi Courts

Source reference: para. 8
02

Issues

Whether the Delhi High Court should exercise its discretionary jurisdiction under Article 226 when the material, essential, and integral cause of action arose outside its territorial limits, notwithstanding that an ancillary part of the cause of action occurred in Delhi

Source reference: para. 6

Whether a contractual agreement between parties regarding jurisdiction is binding upon a Constitutional Court in the exercise of its writ jurisdiction

Source reference: para. 8
03

Law Applied

The court applied the doctrine of forum conveniens, which dictates that even if a small part of a cause of action arises within a High Court's jurisdiction, the court may refuse to exercise its discretionary jurisdiction if it is not the appropriate forum

Source reference: para. 9

This principle was established by the Supreme Court in Kusum Ingots Alloys Ltd. v. Union of India (2004) 6 SCC 254

Source reference: para. 9

The court also relied on The Indure Pvt. Ltd. v. Government of NCT of Delhi (2026:DHC:1605), which held that High Courts should not become "mini-pan-India" courts by entertaining matters where the underlying cause lies elsewhere, regardless of where the final order was passed

Source reference: para. 7

Finally, the court noted that Constitutional Courts are not bound by private jurisdictional agreements between parties but must adjudicate based on constitutional provisions

Source reference: para. 8
04

Reasoning

The Court observed that while the issuance of the contract and termination order from New Delhi constituted a part of the cause of action, these were merely ancillary

Source reference: para. 6, 8

The "material, essential, and integral" cause of action was centered in Punjab, where the transportation services were to be executed

Source reference: para. 6, 10

The Court reasoned that the mere passing of an order within its jurisdiction does not compel the Court to entertain a petition if the events prompting that order occurred elsewhere

Source reference: para. 7

Regarding the Petitioner's argument on the contractual choice of forum, the Court clarified that writ jurisdiction is governed by constitutional principles rather than private contracts, and thus the agreement to submit to Delhi's jurisdiction did not bind the Court

Source reference: para. 8

Consequently, the Court found it appropriate to invoke the doctrine of forum conveniens to decline the matter

Source reference: para. 9-10
05

Holding

The High Court of Delhi declined to entertain the petition and relegated the Petitioner to the jurisdictional High Court where the material cause of action arose

The petition and pending applications were disposed of, with all rights and contentions left open for the Petitioner to pursue in the appropriate forum

Source reference: para. 11-12
Delhi High Court

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M/S R.P. TransportersvsHindustan Petroleum Corp. Ltd. & Ors.

Delhi High Court · April 06, 2026

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