Situs of respondent-authority does not determine territorial jurisdiction if integral cause of action arises elsewhere.

The petitioners, residents of Gurugram, Haryana, sought to quash search and seizure proceedings conducted by the Enforcement Directorate (ED) at their residence in December 2025, along with the "reasons to believe" issued under Section 8(1) of the PMLA

The ED investigation stemmed from a CBI FIR registered in Delhi concerning illegal call centers

However, the ED registered the ECIR at its Zonal Office in Gurugram

All subsequent actions, including multiple searches, seizures of movable property, issuance of summons, and the PMLA trial proceedings, originated from or occurred within Gurugram

The petitioners approached the Delhi High Court claiming territorial jurisdiction based on a bald averment

Whether the High Court of Delhi should exercise its discretionary jurisdiction to entertain a writ petition where the material, essential, and integral part of the cause of action arose outside its territorial limits

The court primarily applied the doctrine of forum non conveniens as established in Kusum Ingots & Alloys Ltd. v. Union of India, which holds that even if a small part of the cause of action arises within a court's jurisdiction, the court may refuse to exercise discretion if it is not the appropriate forum

It further relied on Sterling Agro Industries Ltd. v. Union of India and The Indure Pvt. Ltd. v. Government of NCT of Delhi, affirming that the situs of a respondent-authority’s head office in Delhi does not automatically vest jurisdiction if the underlying dispute and "dominant facts" lie elsewhere

Finally, the court noted that under Vijay Madanlal Choudhary v. Union of India, money laundering is an independent offence from the predicate offence

The court reasoned that the "substance of the matter" must determine territorial jurisdiction rather than the "unchanging constant" of a government authority being located in the national capital

It observed that the petitioners reside in Gurugram, the searches and seizures occurred in Gurugram, the investigating officers are based there, and the PMLA trial is slated for Gurugram

The court rejected the argument that the predicate offence being registered in Delhi conferred jurisdiction, noting that the PMLA offence is independent

The court emphasized that entertaining such petitions based solely on the respondent's location would erroneously transform the Delhi High Court into a "mini-pan-India Superior Court" for events occurring across the country

Since the "material, essential and integral" part of the cause of action arose outside Delhi, the court invoked forum non conveniens

The petition was dismissed for lack of territorial jurisdiction. However, the court granted the petitioners liberty to approach the jurisdictional High Court (Punjab and Haryana High Court) to agitate their grievances, leaving all rights and contentions open