Situs of Central Government alone does not confer territorial jurisdiction when material cause of action arises elsewhere.

The Petitioner, Instapower Ltd., filed a writ petition challenging the rejection of its application for a subsidy under the Central Capital Investment Scheme, 2003, intended for industrial units in Uttarakhand and Himachal Pradesh.

The final communication denying the subsidy was dated 23.09.2024.

The Petitioner argued that since the interpretation of the scheme and the communications regarding entitlement originated in Delhi (where the Central Government is situated), the Delhi High Court possessed the jurisdiction to hear the matter.

Whether the Delhi High Court should exercise its writ jurisdiction under Article 226 of the Constitution when the industrial unit and the material cause of action are located in Uttarakhand, despite the respondent being located in Delhi.

The Court applied the doctrine of forum conveniens and the principles governing territorial jurisdiction under Article 226(2) of the Constitution of India.

Kusum Ingots Alloys Ltd. v. Union of India establishes that even if a small part of the cause of action arises within a court's jurisdiction, the court may refuse to exercise discretionary jurisdiction if a more appropriate forum exists.

Saksham Hospital v. Union of India and The Indure Pvt. Ltd. v. Government of NCT of Delhi clarify that the mere situs of the Central Government or the head office of a respondent does not determine territorial jurisdiction if the "material, essential, and integral" part of the cause of action arose elsewhere.

The Court reasoned that the dispute fundamentally relates to an industrial unit situated in Uttarakhand and its eligibility under a scheme specifically applicable to that State.

While the impugned decision was communicated from Delhi, the Court characterized this as only a "fraction of the cause of action".

The Court noted that all compliance factors and the physical infrastructure subject to the dispute are located outside Delhi.

The Court emphasized that entertaining such petitions based solely on the seat of the Central Government would effectively turn the Delhi High Court into a "mini-pan-India Superior Court," undermining the jurisdiction of the High Courts where the events actually occurred.

Consequently, the Court found that the material, essential, and integral cause of action arose in Uttarakhand.

The petition was dismissed with liberty granted to the Petitioner to approach the jurisdictional High Court (the Uttarakhand High Court) to agitate the matter, and all rights and contentions of the parties were left open.