Situs of Head Office Alone Cannot Confer Jurisdiction Under Forum Conveniens If Material Cause of Action Arises Elsewhere.

The Petitioner, a company engaged in civil construction and toll collection, was awarded a contract by the National Highways Authority of India (NHAI) for user fee collection at a toll plaza situated in Karnataka

Following a Letter of Award dated 05.12.2025 and a work order dated 02.01.2026, toll operations were disrupted on 14.03.2026 due to interference by ex-employees

Despite representations for protection, NHAI (Respondent No. 3) issued an order dated 20.03.2026 terminating the contract

The Petitioner challenged this termination before the Delhi High Court, invoking jurisdiction primarily on the basis that the NHAI headquarters is located in Delhi

1. Whether the mere location of the headquarters of a respondent authority (NHAI) within Delhi is sufficient to confer territorial jurisdiction upon the Delhi High Court when the underlying cause of action arose elsewhere.

2. Whether the Court should decline to exercise jurisdiction under the doctrine of forum conveniens given that the material facts occurred in Karnataka.

The Court relied on the doctrine of forum conveniens and the "material, essential, and integral" part of the cause of action test as established in Alchemist Ltd. v. State Bank of Sikkim

It applied the principle from Sterling Agro Industries Ltd v. Union of India, which mandates that the location of an authority alone does not constitute forum conveniens

Furthermore, it cited Kusum Ingots & Alloys Ltd. v. Union of India, holding that even if a small part of the cause of action arises within a jurisdiction, the Court may refuse to exercise discretionary jurisdiction if it is an inconvenient forum

Internal precedents including The Indure Pvt. Ltd. v. Government of NCT of Delhi were cited to affirm that the situs of the head office is an "unchanging constant" and not a "dominant fact" for jurisdiction

The Court reasoned that the entire substance of the dispute—including the tender issuance, contract execution, performance, and the alleged disruption of toll operations—occurred at the project site in Karnataka

The Court observed that while NHAI is headquartered in Delhi, this is a "static/uniform facet" of the national capital and does not relate to the foundational facts or the legal injury suffered

Applying the "dominant facts" test, the Court found that the material, essential, and integral part of the cause of action arose outside its territorial limits

It noted that entertaining such petitions would erroneously turn the Delhi High Court into a "mini-pan-India Superior Court"

Consequently, even if a minuscule portion of the cause of action (the issuance of the order from Delhi) was assumed, the doctrine of forum conveniens necessitated relegating the party to the jurisdictional High Court

It held that the principal cause of action arose in Karnataka and the Delhi High Court is not the appropriate forum

The petition was dismissed with liberty granted to the Petitioner to approach the jurisdictional High Court in Karnataka

All rights and contentions of the parties were left open