RR Fashion Vs Union of India And Ors (Delhi High Court)
The petitions before the Delhi High Court challenged multiple seizure memos issued by the Directorate of Revenue Intelligence (DRI) in relation to imported goods. The petitioners had imported PVC coated fabrics from a Chinese company through a Special Economic Zone in Tamil Nadu, where the goods were also warehoused. The DRI inspected the goods and issued seizure memos in May 2025, which were served on the petitioners in Chennai. The petitioners further challenged the test reports issued by the Central Revenue Control Laboratory (CRCL), New Delhi.
A preliminary objection was raised by the respondents regarding territorial jurisdiction, contending that the entire cause of action arose in Tamil Nadu since the imports, storage, seizure, and service of seizure memos took place there. The petitioners argued that part of the cause of action arose in Delhi because the DRI office issuing the memos and the testing laboratory were located in Delhi.
The Court examined earlier decisions, including the Full Bench ruling in Sterling Agro Industries Ltd v. Union of India, which clarified that even if a small part of the cause of action arises within a court’s jurisdiction, the court may still decline to exercise jurisdiction based on the doctrine of forum conveniens. The Court emphasized that jurisdiction depends not only on a technical cause of action but also on which forum is most appropriate given the factual matrix.
