Court holds that mere presence of CBIC and DRI headquarters in Delhi does not confer jurisdiction; entire cause of action arose outside Delhi, in Noida/ICD Dadri
In a significant decision dated October 9, 2026, the Delhi High Court (Division Bench) dismissed a writ petition filed by M/s Pradeep Industries challenging the seizure and detention of imported stainless steel coils at the Inland Container Depot (ICD) Dadri, Uttar Pradesh. The Court ruled that it lacked territorial jurisdiction to entertain the petition as the entire cause of action arose outside Delhi, specifically under the jurisdiction of the Commissioner of Customs, Noida.
The petitioners had sought relief against seizure memos issued in May, June, and July 2025, contending that the goods were wrongly classified under Customs Tariff Heading (CTH) 73269060 and that the reliance on a Chartered Engineer (CE) certificate for classification was contrary to CBIC policy. They also highlighted that similar goods were cleared by other ICDs and claimed that since the Central Board of Indirect Taxes and Customs (CBIC) and Directorate of Revenue Intelligence (DRI) headquarters are located in Delhi, the Delhi High Court had jurisdiction.
The respondents argued that the seizure and related proceedings took place entirely at ICD Dadri, which falls under the Commissioner of Customs, Noida, and thus outside the territorial jurisdiction of the Delhi High Court. The Court agreed with the respondents, emphasizing that the cause of action had arisen wholly in Uttar Pradesh, and the presence of CBIC and DRI headquarters in Delhi did not confer jurisdiction on this Court.
The Court extensively analyzed the doctrine of territorial jurisdiction and forum conveniens. It distinguished the present case from precedents where a minuscule part of the cause of action arose within the forum's jurisdiction, allowing the writ petition to be entertained. In this case, there was no part of the cause of action within Delhi. The Court also reviewed a Full Bench decision in Sterling Agro Industries Ltd. v. Union of India and held that the facts of the present case did not attract the principle that even a small part of cause of action arising within the jurisdiction would suffice. It further clarified that the doctrine of forum conveniens was not applicable where there was a complete lack of territorial jurisdiction.
The Court referred to the Supreme Court judgment in Bakshish Ahmad v. Union of India and a recent Division Bench decision in M/s Meever India Private Limited v. Union of India, which supported the dismissal of petitions where the cause of action arose outside Delhi.
Consequently, the Delhi High Court dismissed the writ petition for lack of territorial jurisdiction, directing the petitioners to seek remedies before the appropriate authorities in Noida or other competent forums. The Court also noted that issues regarding the validity of the Chartered Engineer certificate and classification of goods must be decided by the Commissioner of Customs, Noida.
This ruling underscores the importance of territorial jurisdiction in writ petitions and clarifies that the location of headquarters of central agencies like CBIC or DRI does not automatically confer jurisdiction in matters where the cause of action arises elsewhere.
Bottom Line:
Writ petition challenging seizure/detention of imported goods at ICD, Dadri, Uttar Pradesh is not maintainable before Delhi High Court merely because CBIC/DRI headquarters are in Delhi - where no part of cause of action arises within Delhi, petition is liable to be dismissed for lack of territorial jurisdiction.
Statutory provision(s):
Article 226 of the Constitution of India
M/s Pradeep Industries v. Union of India, (Delhi)(DB) : Law Finder Doc Id # 2996370
