Mere Location Of Customs Headquarters In Delhi Does Not Confer Territorial Jurisdiction: Delhi High Court

The Delhi High Court has dismissed a writ petition challenging the seizure of imported stainless-steel coils at the Inland Container Depot (ICD), Dadri, Uttar Pradesh, holding that the location of the Customs Commissionerate's headquarters in Delhi does not confer territorial jurisdiction on the Court when no part of the cause of action has arisen within its jurisdiction.

The Division Bench of Justices Avneesh Jhingan and Shail Jain held that the dispute concerning the seizure of goods and their provisional release fell within the jurisdiction of the Commissioner of Customs, Noida, as the goods were detained at ICD Dadri and the proceedings were pending before the customs authority in Uttar Pradesh.

For context, Petitioners had sought to set aside four seizure memos issued in July and August 2025 and directions for the release or provisional release of the seized goods.

Petitioners had imported designer and decorative stainless-steel coils from China. The goods were seized on the ground that they were incorrectly classified under Customs Tariff Heading (CTH) 73269060 and required certification from the Bureau of Indian Standards (BIS) under IS 6911 in terms of the Steel Control Order issued by the Union Steel Ministry.

Petitioners contended that the detention was contrary to the Central Board of Indirect Taxes and Customs (CBIC) policy and that the certificate issued by a Chartered Engineer could not have been relied upon to determine the classification of the imported goods. They also argued that similar goods had been cleared through other Inland Container Depots.

To establish territorial jurisdiction, Petitioners submitted that the Customs Commissionerate's headquarters was located in Delhi and that the Directorate of Revenue Intelligence (DRI) and CBIC exercised jurisdiction across India.

Rejecting these submissions, the Court observed that the issues concerning the classification of the imported goods, the applicability of BIS certification requirements and the reliance placed on the Chartered Engineer's certificate were matters to be considered by the Commissioner of Customs, Noida.

It held that these contentions could not confer territorial jurisdiction on the Delhi High Court merely because Petitioners alleged violations of CBIC policy or because central authorities were headquartered in Delhi.

The Court further noted that the Full Bench ruling in Sterling Agro Industries Ltd. v. Union of India, (2011) recognised that even where a part of the cause of action arises within a High Court's jurisdiction, the Court may decline to exercise its discretionary jurisdiction by applying the doctrine of forum conveniens. The nature of the cause of action and the appropriate forum must be assessed in light of the facts of each case.

However, the Court found that the present case was one of a lack of territorial jurisdiction, rather than a situation warranting the application of the doctrine of forum non conveniens.

As such, the Court dismissed the writ petition.

For Petitioners: Advocates Govind Krishna Dixit, Anasua Chakravarti, Shubhankar Jha & Sanjeevani Dixit

For Respondents: Advoates Anurag Ojha, SSC with Aditya Chaudhary,for R-4&6/DRI. Avtaar Singh Deol, SPC with Deepak Sharma, Vinay Chadda, Rishabh Gupta & A. Sakthivel, Advs. for R-7. Senior Advocate Dr. Subhash C Gupta, for R-8/BIS. (through VC)