Location of an appellate authority does not confer jurisdiction if the material cause of action arises elsewhere.

The Petitioner, a resident of Noida, Uttar Pradesh, filed an RTI application with the Respondent authority located in Mumbai, seeking information regarding a real estate project situated in Greater Noida West, Uttar Pradesh

Following non-disclosure and an inconclusive First Appeal before the Appellate Authority in Mumbai, the Petitioner preferred a Second Appeal before the Central Information Commission (CIC)

The Petitioner subsequently approached the Delhi High Court to challenge the CIC’s order dated 22.02.2025

1. Whether the Delhi High Court possesses territorial jurisdiction to entertain a writ petition solely because the appellate authority (CIC) is situated in Delhi, despite the primary cause of action arising elsewhere

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

The Court primarily relied on the Supreme Court’s ruling in Siddartha S. Mookerjee and Anr. v. Madhab Chand Mitter and Anr. (2024), which established that the location of a national tribunal or commission (such as the NCDRC or CIC) in Delhi is not a sufficient ground to invoke the Delhi High Court’s jurisdiction if the underlying cause of action arose in another state

The Court further applied the doctrine of forum conveniens as articulated in Kusum Ingots & Alloys Ltd. v. Union of India, which holds that a High Court may refuse to exercise discretionary jurisdiction even if a small part of the cause of action arises within its territory if another forum is more appropriate

The Court noted that the material, essential, and integral cause of action—comprising the Petitioner’s residence, the location of the property in question, and the location of the original Respondent authority—fell entirely outside Delhi

The Court reasoned that under the precedent of Siddartha S. Mookerjee, the mere seat of the CIC in Delhi does not vest the High Court with jurisdiction when the dispute's facts are rooted in Noida and Mumbai

Even assuming a fraction of the cause of action arose in Delhi due to the impugned order's origin, the Court invoked forum conveniens to decline jurisdiction, emphasizing that the location of the adjudicating authority is not a determinative factor for compelling a High Court to hear a matter on merits

It held that the challenge to the CIC order must be brought before the jurisdictional High Court where the integral cause of action arose

The Petitioner was granted liberty to approach the appropriate High Court, with all rights and contentions left open