Delhi High Court

Respondent’s head office location does not confer territorial jurisdiction absent a local cause of action.

Aryan Yadav vs Union Of India And Ors

Delhi High CourtJUDGMENT: April 01, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, a resident of Gorakhpur, Uttar Pradesh, challenged the findings of the Detailed Medical Examination (DME) dated 21.11.2025 and the Review Medical Examination (RME) dated 24.11.2025, which declared him medically unfit (overweight) for the post of Constable (GD) in the CAPFs Examination-2025

Source reference: p. 2

Both medical examinations were conducted in Pune, Maharashtra

Source reference: p. 2

The Petitioner had previously approached the Allahabad High Court, which dismissed his petition but granted liberty to approach a court with appropriate territorial jurisdiction

Source reference: p. 2

Consequently, the Petitioner filed the present writ in the Delhi High Court, contending that jurisdiction existed in Delhi because the Staff Selection Commission (SSC) is headquartered there

Source reference: p. 2
02

Issues

1. Whether the High Court of Delhi has territorial jurisdiction to entertain a challenge against medical examination findings conducted in Pune, Maharashtra, solely because the respondent’s head office is in Delhi?

Source reference: p. 2-3

2. Whether Clause 18 of the recruitment notification restricts territorial jurisdiction to the location where the candidate appeared for the Computer-Based Examination?

Source reference: p. 3
03

Law Applied

The Court applied the doctrine of forum non conveniens, establishing that a small part of the cause of action does not compel a High Court to decide a matter if the "bundle of facts" arose elsewhere

Source reference: p. 4

It relied on Clause 18 of the recruitment notification, which stipulates that disputes are subject to courts having jurisdiction over the place of the Regional Office where the candidate appeared for the Computer-Based Examination

Source reference: p. 3

The Court further cited its own precedents in Anand Kumar v. Union of India & Others (2025:DHC:206-DB) regarding the definition of "cause of action" and Bicky Kumar Mahato v. Union of India & Anr. (W.P. (C) No.3494/2026) regarding territorial jurisdiction in CAPF recruitment

Source reference: p. 3-4
04

Reasoning

The Court determined that no cause of action arose within its territorial jurisdiction

Source reference: p. 3

Although the Petitioner argued that the SSC's location in Delhi conferred jurisdiction, the Court noted that the material facts—the DME and RME—occurred entirely in Pune, Maharashtra

Source reference: p. 2

Referring to Clause 18 of the SSC notification, the Court highlighted that the Petitioner admittedly appeared for the Computer-Based Examination in Pune, thereby anchoring jurisdiction to that region

Source reference: p. 3

The Court reasoned that the "bundle of facts" required to adjudicate the medical unfitness claim pertained to the reports drawn in Pune, not the administrative location of the SSC in Delhi

Source reference: p. 4

Following the principle in Anand Kumar, the Court held that the mere presence of a head office is insufficient to override the site where the actual grievance (medical unfitness) originated

Source reference: p. 4-5
05

Holding

The Court held that it lacks the territorial jurisdiction to entertain the writ petition

It dismissed the petition and pending applications, granting the Petitioner liberty to approach the competent court having territorial jurisdiction over Pune, Maharashtra, to ventilate his grievances against the DME/RME findings

Source reference: p. 5
Delhi High Court

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Aryan YadavvsUnion Of India And Ors

Delhi High Court · April 01, 2026

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