Livelihood and travel inconvenience are insufficient grounds for transferring a civil suit under Section 24 CPC.

The Petitioners (Plaintiffs in Civil Suit No. 75 of 2019) filed an application under Section 24 of the Code of Civil Procedure (CPC) to transfer the suit from the Court of Civil Judge (Senior Division), Salipur to Kendrapara.

Petitioner No. 1, a widow residing in her parental home at Kendrapara with a minor daughter, sought transfer on grounds of financial dependency, lack of male accompaniment, and fear of the Opposite Parties’ influence in Salipur.

The underlying suit involves a challenge to a registered gift deed and a prayer for a permanent injunction regarding property located within the territorial jurisdiction of Salipur.

1. Whether the grounds of personal inconvenience and apprehension of influence are sufficient to transfer a civil suit under Section 24 of the CPC when the suit property is located within the original court's jurisdiction.

2. Whether the availability of modern procedural alternatives, such as video conferencing, mitigates the alleged inconvenience of a party in a transfer petition.

Section 24 of the CPC regarding the general power of transfer.

The Supreme Court precedent Kulwinder Kaur Alias Kulwinder Gurcharan Singh v. Kandi Friends Education Trust (2008) 3 SCC 659, which establishes that transfer grounds include the balance of convenience, the interest of justice, and the reasonable apprehension of not receiving a fair trial, though these are illustrative and not exhaustive.

Orissa High Court Video Conferencing for Courts Rules, 2020 and Order 26, Rule 4 of the CPC regarding the examination of witnesses on commission.

Indian Overseas Bank v. Chemical Construction Company (1979) 4 SCC 358 regarding the standards for transfer.

The court reasoned that the grounds urged—lack of a male escort and financial hardship—were not "convincing" enough to warrant a transfer.

It noted that the Petitioners themselves originally chose the Salipur forum in 2019, which is the court with territorial jurisdiction over the suit property.

The court highlighted that as Plaintiffs, the Petitioners are not required to be physically present for every hearing since they are represented by counsel.

The court emphasized that any genuine physical or logistical inconvenience during the evidentiary stage could be adequately addressed through technological or procedural means, such as Video Conferencing or examination by Commission, rather than uprooting the entire proceeding.

The court granted liberty to the Petitioners to move the trial court at Salipur for leave to depose via Video Conferencing or for the appointment of a Commission to record evidence should the need arise during the trial.