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

In brief

The question

1. Whether the Delhi High Court should exercise jurisdiction over a writ petition challenging an order of a Central Authority located in Delhi when the material cause of action arose entirely outside its territorial limits?

The court held

The court dismissed the petition on the grounds of lack of territorial jurisdiction and forum conveniens.

It also directed

The court held that the petitioner must approach the jurisdictional High Court where the cause of action arose.

Liberty was granted to the petitioner to agitate the matter before the appropriate High Court, with all rights and contentions left open.

01Facts

The petitioner, a resident of Kolkata, West Bengal, filed an RTI application with the Central Public Information Officer (CPIO) of the Union Bank of India, Mumbai, seeking information regarding a loan account of a third party.

¶ 2

Following a non-disclosure response and an unsuccessful first appeal before the First Appellate Authority in Mumbai, the petitioner preferred a Second Appeal before the Central Information Commission (CIC) in New Delhi.

¶ 2

The CIC passed the impugned order on 27.05.2025.

¶ 1, 2

The petitioner subsequently challenged the CIC's order before the Delhi High Court on the ground that the CIC is situated within its territorial jurisdiction.

¶ 4

02Issues

i.1. Whether the Delhi High Court should exercise jurisdiction over a writ petition challenging an order of a Central Authority located in Delhi when the material cause of action arose entirely outside its territorial limits?

¶ 5

ii.2. Whether the doctrine of forum conveniens permits the High Court to refuse discretionary jurisdiction even if a part of the cause of action arises within its territory?

¶ 6

03Law Applied

The court primarily applied the principle established in Siddartha S. Mookerjee and Anr. v. Madhab Chand Mitter and Anr., which held that the location of an appellate or revisional authority (such as the NCDRC or CIC) in Delhi does not, by itself, vest jurisdiction in the Delhi High Court if the underlying cause of action arose elsewhere.

¶ 4-5

The court further relied on Kusum Ingots & Alloys Ltd. v. Union of India and Anr., which established the doctrine of forum conveniens, affirming that a High Court may refuse to exercise discretionary jurisdiction if only a minuscule part of the cause of action arises within its territory and a more appropriate forum exists.

¶ 6

Provisions in the judgment · 1 · Linked ones open on LawLens

Right to Information Act, 2005 Section 19

04Reasoning

The court observed that the petitioner is based in Kolkata, the respondent bank is in Mumbai, and the subject matter of the RTI (the loan account) pertains to a Mumbai-based entity.

¶ 2

Consequently, the integral and material cause of action arose outside Delhi.

¶ 5

The court reasoned that the mere fact that the CIC—the authority that passed the impugned order—is situated in Delhi is insufficient to invoke the jurisdiction of the Delhi High Court.

¶ 4

Citing the Kusum Ingots precedent, the court emphasized that even if the seat of the appellate body provides a technical nexus to Delhi, the court should invoke the doctrine of forum conveniens to decline the matter when the "essential and integral" facts of the dispute are situated elsewhere.

¶ 5, 6