Situs of Revisional Authority alone does not attract jurisdiction under the doctrine of forum conveniens.

The Petitioner, SAIL, challenged an order dated 06.05.2024 passed by the Revisionary Authority (Union of India) under Section 30 of the MMDR Act and Rule 36 of the Mineral Concession Rules, 2016.

The dispute originated from a demand notice issued by the State of Odisha on 25.01.2023 regarding a shortage of limestone at the Purnapuri Quarry situated in Odisha.

The Revisionary Authority, located in New Delhi, rejected the Petitioner's revision on the grounds of maintainability under Section 23C(3) of the MMDR Act.

The Petitioner approached the Delhi High Court seeking a writ of certiorari to quash the revisionary order.

Whether the Delhi High Court should exercise its jurisdiction under Articles 226 and 227 of the Constitution based solely on the location of the Revisionary Authority in Delhi, or whether the doctrine of forum conveniens applies.

Whether the challenge is maintainable in Delhi when the entire cause of action (mining lease, alleged shortage, and demand notice) arose in the State of Odisha.

The Court primarily applied the doctrine of forum conveniens as established by the Full Bench of the Delhi High Court in M/s Sterling Agro Industries Ltd. v. Union of India.

This precedent modified the earlier view in New India Assurance Co. Ltd. v. Union of India, clarifying that the mere situs of a Tribunal or Revisionary Authority does not compel a High Court to entertain a petition if the primary cause of action lies elsewhere.

The Court also referenced Alchemist Ltd. v. State Bank of Sikkim regarding the nature of the "cause of action".

The court acknowledged the distinction between Articles 226 and 227 as argued by the Petitioner through Vishnu Security Services v. Regional P.F. Commissioner.

The Court noted that the mines are located in Odisha, the alleged limestone shortage occurred there, and the resulting demand notice was issued by the State of Odisha; therefore, the integral and material part of the cause of action arose in Odisha.

The Petitioner's sole ground for invoking Delhi's jurisdiction was the location of the Revisionary Authority in the capital.

Applying the Sterling Agro ratio, the Court reasoned that while an appellate order constitutes a part of the cause of action, it is not a singular factor that mandates the High Court to decide the matter on merits.

The Court found that exercising discretionary jurisdiction would be inappropriate where the factual matrix and the primary lis are centered in another state.

It held that the involvement of the Delhi High Court was not justified simply because the Revisionary Authority is situated in New Delhi.

Liberty was granted to the Petitioner to approach the jurisdictional High Court (Odisha), with all rights and contentions left open.