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

The petitioner, a construction company, was awarded a contract by Respondent No. 1 for civil and plumbing works at a hospital in Kendrapara, Odisha, via a 2020 Work Order

The petitioner claims the work was completed on 02.12.2022 and the facility is operational; however, the respondents refuse to issue a Completion Certificate or release retention money

Instead, respondents directed the extension of a Performance Bank Guarantee (PBG) of approx. Rs. 1.02 Crores, citing "anticipated risk and cost recovery" from a separate terminated contract

While the project and alleged deficiencies occurred in Odisha, the petitioner approached the Delhi High Court on the basis that the respondents' corporate office is located in Delhi

1. Whether the mere location of a respondent’s registered or corporate office within the court’s territory is sufficient to vest territorial jurisdiction when the material cause of action arose elsewhere

2. Whether the court should exercise its discretionary jurisdiction under the doctrine of forum non conveniens when the "dominant facts" of the dispute are centered in another state

The court applied the principle that the situs of a head office does not, by itself, determine territorial jurisdiction for a writ petition

The Indure Pvt. Ltd. v. Government of NCT of Delhi, which established that courts must look for "material, essential, and integral" facts rather than "unchanging constants" like the location of a national capital authority

Kusum Ingots Alloys Ltd. v. Union of India, which held that even if a small part of the cause of action arises within a jurisdiction, the court may refuse to entertain the matter by invoking the doctrine of forum conveniens

The Court reasoned that all substantial elements of the dispute—including the contract execution, alleged completion, defect liability, and the physical project site—are located in Kendrapara, Odisha

It observed that in a national capital like Delhi, many authorities have a pan-India presence, but the act of passing an order or holding a hearing in Delhi is often "immaterial" and "non-integral" to the actual legal injury

The Court emphasized that it must judge the "substance of the matter" rather than "static/uniform facets"

Since the "dominant facts" and the foundational legal injury occurred in Odisha, the Court found no justification to act as a "mini-pan-India Superior Court" for events occurring entirely outside its borders

The writ petition and pending applications were dismissed on the grounds of forum non conveniens

The Court granted the petitioner liberty to approach the appropriate jurisdictional High Court (Odisha) to agitate the matter, leaving all rights and contentions open