Situs of authority is insufficient for territorial jurisdiction if the material cause of action arises elsewhere.

The Petitioner (NMDC Limited) was allotted the Rohne Coal Mine in Jharkhand through an auction process under the Mines and Minerals (Development and Regulation) Act, 1957

An Allotment Agreement was executed on 17.02.2021 between the Petitioner and the Nominated Authority (NA)

The Respondent issued a Show Cause Notice (SCN) dated 04.06.2024, proposing the forfeiture and invocation of the Petitioner’s Performance Bank Guarantee due to alleged delays in commencement of mining operations

The Petitioner challenged this SCN before the Delhi High Court, asserting jurisdiction on the sole ground that the office of the NA is situated in Delhi

1. Whether the mere location of the head office or decision-making authority of a Respondent within the territorial limits of a High Court is sufficient to vest that Court with jurisdiction when the subject matter and underlying cause of action arose elsewhere.

2. Whether the Delhi High Court is the forum conveniens to adjudicate a dispute concerning a mining block situated in the State of Jharkhand.

The Court primarily applied the principle of forum non conveniens and the "material, essential, and integral part of cause of action" test established in Kusum Ingots Alloys Ltd. v. Union of India

It relied on Sterling Agro Industries Ltd v. Union of India, which held that the location of an authority alone does not constitute forum conveniens

Furthermore, it applied the "dominant facts" theory from The Indure Pvt. Ltd. v. Government of NCT of Delhi, which mandates that the substance of the matter, rather than the static location of a government authority in the national capital, determines territorial jurisdiction

The Court reasoned that although the Nominated Authority is located in Delhi, the subject coal mine is situated in Jharkhand, and the statutory approvals and clearances relevant to the dispute were to be obtained from authorities in Jharkhand

The Court observed that the act of passing an order or issuing a notice from Delhi is an "unchanging constant" due to Delhi's status as the capital and does not constitute a "material/integral" part of the cause of action

Citing previous orders in Orissa Alloy Steel and Vedanta Ltd., the Court found that when the underlying facts and legal injury are rooted in events outside Delhi, the High Court should not act as a "mini-pan-India Superior Court"

The Court emphasized that the "dominant facts" of the case were centered in Jharkhand, making the jurisdictional High Court of that state the appropriate forum

The petition was dismissed with liberty granted to the Petitioner to approach the jurisdictional High Court of Jharkhand. All rights and contentions of the parties were left open