Delhi High Court

Situs of NCDRC does not confer jurisdiction if the underlying cause of action arose elsewhere.

Patiala Lace House Through Its Proprietor vs The New India Assurance Through Its Branch Manager And Ors.

Delhi High CourtJUDGMENT: March 28, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, a proprietary concern, filed a writ petition under Article 226/227 seeking to set aside an order dated 31.08.2022 passed by the State Consumer Disputes Redressal Commission (SCDRC), Punjab

Source reference: para. 1(a)

Additionally, the Petitioner sought a writ of mandamus for the payment of an insurance claim amounting to Rs. 60,00,000, along with compensation and litigation expenses

Source reference: para. 1(b)-(c)

The underlying dispute originated from a complaint filed before the District Consumer Disputes Redressal Forum, Mansa, Punjab, which was subsequently appealed before the SCDRC, Punjab

Source reference: para. 5

The Petitioner approached the Delhi High Court on the sole ground that the National Consumer Disputes Redressal Commission (NCDRC), which entertained the revision petition, is situated in Delhi

Source reference: para. 2
02

Issues

Whether the Delhi High Court has the territorial jurisdiction to entertain a writ petition challenging orders arising from consumer disputes where the entire cause of action occurred in another state, solely because the NCDRC is located in Delhi?

Source reference: para. 2, 8
03

Law Applied

The Court relied on the Supreme Court’s decision in Siddharth S. Mookerjee and Anr. v. Madhab Chand Mitter and Anr. (2024 SCC OnLine SC 4285), which held that the location of the NCDRC does not vest jurisdiction in the Delhi High Court if the cause of action arose elsewhere

Source reference: para. 6

It further applied the principle from General Manager Punjab National Bank and Ors. v. Rohit Malhotra (2024:DHC:7035), affirming that the situs of a Tribunal or Authority exercising control over multiple states is not a deciding factor for jurisdiction

Source reference: para. 7

The court also referenced Ibrat Faizan v. Omaxe Buildhome Private Limited, clarifying that the "concerned High Court" or "jurisdictional High Court" under Article 227 refers to the court under whose territorial jurisdiction the dispute arose

Source reference: para. 7
04

Reasoning

The Court observed that the entire cause of action—including the filing of the initial complaint, the adjudication by the District Forum in Mansa, and the subsequent appeal before the State Commission—transpired outside the territorial jurisdiction of Delhi

Source reference: para. 8

Justice Kaurav reasoned that the NCDRC is a National Authority, and its physical location in the capital is incidental to its function over multiple states

Source reference: para. 8

Relying on the extracted precedents, the Court determined that the Petitioner must approach the High Court under whose jurisdiction the dispute actually arose (the Punjab and Haryana High Court) rather than the Delhi High Court

Source reference: para. 3, 9

The mere fact that a revisionary body (NCDRC) is seated in Delhi does not override the requirement of a territorial nexus with the cause of action

Source reference: para. 8
05

Holding

The Court held that the petition was not maintainable before the Delhi High Court for want of territorial jurisdiction

The petition was dismissed, with liberty granted to the Petitioner to approach the appropriate jurisdictional High Court

Source reference: para. 9

All rights and contentions of the parties were left open

Source reference: para. 10
Delhi High Court

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Patiala Lace House Through Its ProprietorvsThe New India Assurance Through Its Branch Manager And Ors.

Delhi High Court · March 28, 2026

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