Situs of authority is not the sole determinative factor for exercising jurisdiction under Article 226.

The Petitioner, a 72-year-old advocate and Notary Public practicing in Ahmednagar, Maharashtra, since 1979

challenged an Inquiry Report dated June 11, 2025, and a subsequent order dated December 22, 2025, passed by the Central Government, which cancelled his Certificate of Practice and removed his name from the Register of Notaries

The proceedings stemmed from allegations of professional misconduct regarding the improper notarization of photocopies for the Rays Foundation Trust in February 2022

Although an FIR was registered in Ahmednagar against certain trustees for forgery, the Petitioner was not initially implicated, and a local police inquiry against him was closed

However, a complaint was filed with the Notary Cell in Delhi, leading to an inquiry which concluded that the notarization was ante-dated and the Notarial Register was not produced

The Petitioner approached the Delhi High Court seeking a writ of certiorari and mandamus to restore his certificate, primarily because the respondent authority is situated in Delhi

1. Whether the Delhi High Court should exercise its discretionary jurisdiction under Article 226 of the Constitution when the material and integral parts of the cause of action arose outside its territorial jurisdiction

2. Whether the situs of the respondent authority or the passing of an order in the national capital is sufficient to compel the Court to entertain a writ petition under the doctrine of forum conveniens

The Court relied on the doctrine of forum conveniens as established in Sterling Agro Industries Ltd. v. Union of India, which mandates that the situs of the authority passing an order cannot be the sole determinative factor for jurisdiction

It applied the principles from Kusum Ingots & Alloys Ltd. v. Union of India, holding that even if a small part of the cause of action arises within a Court’s jurisdiction, the Court may refuse to exercise discretionary power if the forum is inconvenient

Furthermore, the Court cited The Indure Pvt. Ltd. v. Government of NCT of Delhi, which clarifies that the location of a head office or the act of passing an order in Delhi is an "unchanging constant" and does not constitute a "dominant" or "integral" fact if the underlying events occurred elsewhere

The Court observed that the entire factual matrix—including the notarization, the FIR, the police inquiry, and the alleged professional misconduct—took place in Ahmednagar, Maharashtra, which is outside the Court's territorial jurisdiction

While the final order was passed by the Central Government in Delhi, the Court reasoned that the material, essential, and integral parts of the cause of action were rooted in Maharashtra

The Court emphasized that making the Delhi High Court a "mini-pan-India Superior Court" solely because central authorities are located in the capital would ignore the substance of the matter

It held that the act of passing an order or granting a hearing in Delhi is merely a result of the authority’s location and is "immaterial, non-essential, and non-integral" to the actual dispute

Therefore, the static presence of a respondent in Delhi does not outweigh the factual connection of the lis to another jurisdiction

It held that although a minuscule part of the cause of action (the passing of the order) occurred in Delhi, the dominant facts lay in Maharashtra

The Court granted the Petitioner liberty to approach the jurisdictional High Court (Bombay High Court) to agitate the matter, while leaving all rights and contentions open