Situs of Authority In Delhi At Most Secondary To Material Cause Of Action For Determining Jurisdiction

The petitioner filed a writ petition seeking a Mandamus to compel the Central Vigilance Commission (CVC) to conduct an independent inquiry into a complaint dated 01.04.2024 regarding a dealer of Hindustan Petroleum Corporation Limited (HPCL) operating "Akash Filling Station" in Ujjain, Madhya Pradesh.

The petitioner also challenged the CVC's action of forwarding the complaint to Respondent No. 2 for "necessary action" rather than conducting its own inquiry.

The petitioner approached the Delhi High Court primarily on the basis that the CVC’s headquarters is situated in Delhi.

1. Whether the mere location of the Respondent-Authority’s office in Delhi is sufficient to vest territorial jurisdiction in the Delhi High Court when the underlying cause of action arose elsewhere.

2. Whether the court should exercise its discretionary jurisdiction under the doctrine of forum conveniens.

The Court applied the principle that the situs of a respondent authority is not the sole factor for determining jurisdiction, as established in Indure Pvt. Ltd. v. Government of NCT of Delhi and Ors. (2026:DHC:1605), which emphasizes that jurisdiction depends on where the "material, integral, and essential part" of the cause of action arises.

It further relied on the Supreme Court’s decision in Kusum Ingots & Alloys Ltd. v. Union of India (2004) 6 SCC 254, which held that even if a small part of the cause of action arises within a court's territory, the court may refuse to exercise jurisdiction by invoking the doctrine of forum conveniens.

The Court reasoned that the focal point of the dispute—the operation of an HPCL dealership—is situated in Ujjain, Madhya Pradesh, which is outside the Court's territorial limits.

Following the "dominant facts" test from Indure Pvt. Ltd., the Court observed that the act of an authority passing an order or maintaining a head office in the national capital is often non-essential to the actual legal injury.

The Court determined that since the foundational facts and the subject matter of the complaint occurred outside Delhi, entertaining the petition would result in the Delhi High Court improperly becoming a "mini-pan-India Superior Court".

Consequently, applying the doctrine of forum conveniens, the Court found it inappropriate to adjudicate a matter where the integral cause of action lay in another state.

It held that the Delhi High Court lacks the appropriate territorial jurisdiction as the material cause of action arose in Madhya Pradesh.

The Petitioner was granted liberty to approach the jurisdictional High Court, and all rights and contentions were left open.