### Part of Cause of Action Arising Within Jurisdiction Ousts Mere Administrative Address in Territorial Jurisdiction Determinations

The Appellant (original Plaintiff), an IATA-approved freight forwarder, filed a recovery suit for Rs. 14,15,144/- against the Respondent (Defendant) for unpaid dues related to shipment services.

The Plaintiff alleged that while an oral contract existed, consignments were handed over at its Delhi office, payments were received in Delhi, and cheques issued from the Defendant’s Delhi-based bank account were dishonored upon presentation in Delhi.

Despite the Defendant’s registered office being located in New Delhi, the Trial Court returned the plaint under Order VII Rule 10 of the CPC, ruling that the cause of action accrued in Mumbai because certain invoices and airway bills reflected a Mumbai administrative address.

The Defendant was proceeded ex-parte during the trial proceedings.

1. Whether the Trial Court had territorial jurisdiction to entertain the suit under Section 20 of the CPC based on the location of the Defendant's registered office and the accrual of the cause of action.

2. Whether the mention of an administrative office on invoices can oust the jurisdiction of the place where the registered office is situated and where part of the cause of action arose.

Section 20 of the CPC, which provides that a suit may be instituted where the defendant resides, carries on business, or where the cause of action, wholly or in part, arises.

Section 20(c) CPC, emphasizing that even a partial accrual of the cause of action confers jurisdiction.

Rameshwar Das Dwarka Das (P) Ltd. v. Deepak Puematics (P) Ltd. to establish that the place where an order is placed constitutes a place of accrual.

M/s Auto Movers v. Luminous Power Technologies Pvt. Ltd., upholding the common law principle that "the debtor must seek the creditor," meaning the place where payment is due or where the creditor’s bank is located confers jurisdiction.

The High Court found that the Trial Court erred by ignoring uncontroverted evidence and pleadings.

The court noted that the Defendant's registered office, as per Master Data, was in New Delhi; hence, jurisdiction resided in Delhi under Section 20(a) CPC regardless of the Mumbai administrative office.

Applying Section 20(c), the court observed that several material facts—handing over of consignments, oral agreement, maintenance of ledgers, and the dishonor of cheques—all occurred in Delhi.

The Court reasoned that at the stage of Order VII Rule 10 CPC, the court must presume the averments in the plaint to be correct, and since the Defendant's ex-parte status left the Plaintiff's testimony unrebutted, the Trial Court could not discard these facts based on mere presumptions regarding the Mumbai address on invoices.

The appeal was allowed, the suit was restored to its original position, and the parties were directed to appear before the Trial Court on 28.05.2026.