M/S Pradeep Industries & Ors. vs. Union of India & Ors.
Background
The petitioners' imported stainless-steel coils were seized at the Inland Container Depot (ICD), Dadri, Uttar Pradesh, on the ground that the goods were wrongly classified and lacked required BIS certification. They filed a writ petition in the Delhi High Court, arguing Delhi had jurisdiction because the all-India customs/DRI headquarters are based there.
Decision Breakdown
The Court held that the entire chain of events, the seizure, the classification dispute, and the rejection of provisional release, occurred entirely at ICD Dadri, within the jurisdiction of the Commissioner of Customs, Noida, and not even a small part of the cause of action had actually arisen in Delhi. Relying on an earlier Full Bench ruling of the same Court and a comparable Division Bench precedent, it held that simply having a headquarters office located in Delhi does not by itself confer jurisdiction on the Delhi High Court. The petition was dismissed purely for lack of territorial jurisdiction, with liberty for the petitioner to pursue the correct forum.
Lesson Learnt
When challenging action taken by a government authority located outside Delhi, the mere fact that the department's head office sits in Delhi is not enough to bring the case to the Delhi High Court: the case must generally be filed where the actual facts and decision took place.