Situs of Regulatory Body in National Capital Alone Does Not Confer Territorial Jurisdiction Under Forum Conveniens.

The petitioner, a resident of Tamil Nadu, filed a writ petition seeking a direction to the Rehabilitation Council of India (Respondent No. 1) to decide on his complaint regarding alleged professional misconduct by Dr. Priya Puri (Respondent No. 2), a clinical psychologist based in Kolkata.

The complaint arose from opinions provided by Respondent No. 2 during matrimonial proceedings between the petitioner and his wife in West Bengal.

The petitioner had previously filed a criminal defamation case against Respondent No. 2 in Barasat, West Bengal, the proceedings of which were stayed by the High Court of Calcutta.

The petitioner approached the Delhi High Court solely on the ground that the head office of Respondent No. 1 is situated in Delhi.

1. Whether the mere situs of the registered office or head office of a statutory authority within the territory of Delhi is sufficient to invoke the writ jurisdiction of the Delhi High Court when the underlying cause of action arose elsewhere.

2. Whether the court should exercise its discretionary jurisdiction under the doctrine of *forum non conveniens* despite a small part of the cause of action (the seat of the authority) being in Delhi.

The Court applied the principle that the situs of a head office does not automatically determine territorial jurisdiction, as established in *The Indure Pvt. Ltd. v. Government of NCT of Delhi* and *Michael Builders and Developers Pvt. Ltd. v. National Medical Commission*.

It emphasized the requirement of "dominant facts" and "material, essential, and integral" facts occurring within the jurisdiction to justify entertaining a lis.

Furthermore, the Court relied on the Supreme Court’s decision in *Kusum Ingots & Alloys Ltd. v. Union of India*, which permits a High Court to refuse exercise of discretionary jurisdiction by invoking the doctrine of *forum conveniens* even if a small part of the cause of action arises within its territory.

The Court reasoned that being the national capital, Delhi hosts numerous pan-India statutory bodies, but the act of passing an order or holding a hearing in Delhi is an "unchanging constant" that is often immaterial to the actual legal injury.

In this case, the petitioner is from Tamil Nadu, the therapist functions in Kolkata, and the underlying litigation (matrimonial and criminal) is situated in West Bengal; therefore, the "dominant facts" are entirely outside Delhi.

The Court observed that entertaining such petitions would effectively turn the Delhi High Court into a "mini-pan-India Superior Court," which is not the intent of Article 226.

Applying the doctrine of *forum conveniens*, the Court found that Delhi was not the appropriate forum to adjudicate a dispute where the substance of the matter lacked a significant connection to the territory.

The petition was dismissed on the grounds of territorial jurisdiction and *forum non conveniens*.

Liberty was granted to the petitioner to approach the appropriate jurisdictional High Court (e.g., Calcutta or Madras) to agitate the matter.