Situs of Respondent Authority Alone Does Not Confer Territorial Jurisdiction Under Doctrine of Forum Conveniens.

The petitioner was approved for a grant-in-aid under the Pradhan Mantri Kisan Sampada Yojana for setting up a soymilk and tofu unit in Uttarakhand.

Per the Unit Scheme guidelines, the petitioner furnished a bank guarantee (BG) of Rs. 25,00,000.

On 11.07.2024, the Respondent (Ministry of Food Processing Industries) cancelled the grant and forfeited the BG due to project delays.

The petitioner challenged this forfeiture, attributing delays to land possession issues and heavy rainfall in Uttarakhand.

The petitioner invoked the Delhi High Court's jurisdiction on the basis that the Respondent Ministry is situated in Delhi.

Whether the mere location of a statutory authority’s head office within the Court's territory is sufficient to confer territorial jurisdiction when the underlying cause of action arose elsewhere.

Whether the Court should exercise its discretionary jurisdiction under the doctrine of forum non conveniens despite a small part of the cause of action arising in Delhi.

The Court applied the principles of territorial jurisdiction under Article 226 of the Constitution, emphasizing that the situs of a respondent’s head office does not automatically determine jurisdiction.

It relied on The Indure Pvt. Ltd. v. Government of NCT of Delhi, which holds that courts must look at "material, essential, and integral" facts rather than "unchanging constants" like the location of a Ministry.

Furthermore, it applied the doctrine of forum conveniens as established in Kusum Ingots & Alloys Ltd. v. Union of India, which allows a High Court to refuse a matter if it is not the appropriate forum, even if a fraction of the cause of action arises within its limits.

The Court reasoned that the substance of the dispute—pertaining to the construction and delays of a plant in Uttarakhand—lies outside its territorial limits.

It noted that if every decision made by a Central Ministry in Delhi were challenged in the Delhi High Court, it would effectively become a "mini-pan-India Superior Court".

The Court observed that the act of passing an order or holding a hearing in the national capital is a "static facet" and "immaterial" to the actual legal injury, which in this case occurred in Uttarakhand.

Therefore, even if a minuscule part of the cause of action arose in Delhi by virtue of the Ministry's location, the "dominant facts" pointed toward Uttarakhand as the proper forum.

The Court held that the location of the Union Ministry cannot be the sole reason to entertain the petition when the project and alleged delays occurred elsewhere.

Liberty was granted to the petitioner to approach the jurisdictional High Court (Uttarakhand) to agitate the matter.