Location of Union Ministry’s headquarters does not confer territorial jurisdiction if the cause of action arises elsewhere.

The petitioner sought a writ of mandamus for the correction of his date of birth (from 09.09.2003 to 09.11.2003) and the removal of 'ECR' status in his passport

The petitioner was born in Agra, Uttar Pradesh, where his birth certificate was issued and subsequently corrected by the Agra Municipal Corporation

His passport was originally issued and renewed by the Regional Passport Office (RPO), Ghaziabad, Uttar Pradesh

Upon attaining majority, his request for correction was rejected by the RPO Ghaziabad via an impugned communication dated 04.08.2025

The petitioner challenged this rejection in the Delhi High Court on the basis that the Ministry of External Affairs (MEA), which exercises administrative control over RPOs, is situated in Delhi

Whether the High Court of Delhi has the territorial jurisdiction under Article 226 of the Constitution of India to entertain the petition when the cause of action and the concerned authorities are located in Uttar Pradesh

Article 226(2) of the Constitution of India, which stipulates that jurisdiction is determined by where the "cause of action" arises

Kusum Ingots & Alloys Ltd. v. Union of India, establishing that the mere location of the seat of the Union Government does not confer jurisdiction unless an integral part of the cause of action arises within the court's territory

The doctrine of forum conveniens, as affirmed in State of Goa v. Summit Online Trade Solutions (P) Ltd.

Sterling Agro Industries Ltd. v. UOI, which allows a court to refuse jurisdiction if another High Court is better equipped to deal with the matter

The court reasoned that the "entire bundle of material facts" occurred in Uttar Pradesh: the birth certificate was issued/corrected in Agra, the passport was processed in Ghaziabad, and the petitioner resides in Uttar Pradesh

The court rejected the petitioner's argument that the MEA’s presence in Delhi conferred jurisdiction, citing Kusum Ingots to clarify that the location of an administrative head office is insufficient if the operative executive action—in this case, the RPO Ghaziabad’s refusal—occurred elsewhere

Following the precedent in Suresh Kumar v. Union of India, the court found that since the petitioner and the specific Passport Office are outside Delhi, the Delhi High Court is not the appropriate forum

It held that no part of the cause of action arose in Delhi

The petitioner was granted liberty to approach the appropriate forum, specifically the High Court of Judicature at Allahabad