Mere location of Ministry headquarters in Delhi does not confer territorial jurisdiction absent integral cause of action.

The Petitioner, a joint venture partner, was awarded a contract for the rehabilitation and upgradation of NH-66 in Maharashtra by Respondent No. 5 (Chief Engineer, PWD, Maharashtra)

During execution, a flyover span collapsed at Chiplun, Maharashtra

Following a committee report, the Ministry of Road Transport and Highways (MoRTH) issued a show cause notice through its Ratnagiri office, proposing debarment and a penalty

Subsequently, Respondent No. 2 (DG, MoRTH, New Delhi) approved the action, which was communicated by Respondent No. 3 (Regional Office, Mumbai) and implemented via an impugned circular issued by Respondent No. 4 (Navi Mumbai)

The Petitioner challenged the debarment and penalty in the Delhi High Court, arguing that since the MoRTH is headquartered in Delhi and the final decision-making power rested there, the court had jurisdiction

1. Whether the Delhi High Court has the territorial jurisdiction to entertain the writ petition under Article 226 of the Constitution when the project, incident, and implementing authorities are located in Maharashtra

2. Whether the fact that the central ministry is headquartered in Delhi and the decision-making process occurred there constitutes a "material" or "integral" part of the cause of action

Article 226(2) of the Constitution of India, which mandates that jurisdiction is determined by where the cause of action arises, wholly or in part

Kusum Ingots & Alloys Ltd. v. Union of India, which established that the mere seat of the Government does not confer jurisdiction and introduced the doctrine of forum conveniens

State of Goa v. Summit Online Trade Solutions (P) Ltd., holding that only material, essential, or integral facts constitute a cause of action

Ueta, Inc. & Ors. v. Union of India that corporate headquarters/ministry locations do not automatically vest jurisdiction if all subsequent activities occurred outside that territory

The court reasoned that the "bundle of material facts" occurred entirely within Maharashtra: the project site was in Maharashtra, the accident occurred there, the petitioner is based in Thane, and the specific impugned communication and circular were issued by offices in Mumbai and Navi Mumbai

The court rejected the Petitioner's argument that MoRTH’s Delhi headquarters provided jurisdiction, stating that such an interpretation would improperly allow every National Highway dispute in India to be litigated in Delhi

Applying the doctrine of forum conveniens, the court found that even if a "slender" part of the administrative approval happened in Delhi, the substance of the matter and the relevant authorities were situated in Maharashtra

The writ petition was dismissed for lack of jurisdiction, with liberty granted to the Petitioner to approach the appropriate High Court

Under the doctrine of forum conveniens, the Court refused to exercise its discretionary jurisdiction