Situs of respondent's head office does not confer territorial jurisdiction when cause of action arises elsewhere.

In 2018, GAIL Gas Ltd. awarded a tender to the Petitioner for laying an underground steel pipeline network in Ranchi, Jharkhand.

Following disputes and a purported Letter of Award in 2019, the Petitioner commissioned the pipeline and received a Modified Execution Certificate from a third-party engineering firm.

The Petitioner completed further work on a 3.567 km stretch in 2024 and subsequently sought an Execution Certificate from the Respondent.

The Petitioner approached the Delhi High Court seeking a direction to the Respondent to issue said certificate, asserting jurisdiction solely on the basis that the Respondent’s office is located in Delhi.

1. Whether the mere location of a Respondent’s head office or registered office within the territory of a High Court is sufficient to confer territorial jurisdiction when the underlying cause of action arose elsewhere.

2. Whether the court should exercise its discretionary jurisdiction under the doctrine of forum non conveniens when only a negligible part of the cause of action arises within its jurisdiction.

The Court applied the principle that the situs of a respondent’s office does not per se determine territorial jurisdiction, as established in The Indure Pvt. Ltd. v. Government of NCT of Delhi and Shristi Udaipur Hotels v. HUDCO.

It emphasized the "dominant facts" test, focusing on whether the facts within the jurisdiction are "material, essential, and integral" to the lis.

The Court relied on the Supreme Court’s decision in Kusum Ingots & Alloys Ltd. v. Union of India, which held that even if a small part of the cause of action arises within a court's territory, the court may refuse to exercise discretionary jurisdiction by invoking the doctrine of forum conveniens.

The Court reasoned that the entire subject matter of the dispute—the pipeline project and the execution of work—took place in Ranchi, Jharkhand.

It observed that in the national capital, many authorities have offices, but this "unchanging constant" is non-integral to the actual legal injury or the foundational facts of a case.

The Court noted that entertaining such petitions would effectively turn the Delhi High Court into a "mini-pan-India Superior Court" over events occurring across the country.

Applying the substance-over-form approach, the Court found that while a fractional part of the cause of action might exist in Delhi due to the Respondent's location, the "dominant" and "material" aspects of the dispute were situated entirely outside its borders.

Invoking the doctrine of forum non conveniens, the Court dismissed the petition but granted liberty to the Petitioner to approach the appropriate jurisdictional High Court and left all rights and contentions open.