Baksish Ahmadv.Union of India and Another

Legal Analysis: Baksish Ahmad v. Union of India and Another

Citation: 2026 INSC 630

Court: Supreme Court of India

Bench: A Division Bench comprising Justice Dipankar Datta & Justice Satish Chandra Sharma

Date of Decision: June 9, 2026

Nature of Judgment: Civil Appeal arising out of SLP (Civil) Nos. 855-856 of 2026 against the judgment of the High Court of Delhi at New Delhi dated 10th January 2025 in Writ Petition (C) No. [not specified] and order dated 29th August 2025 dismissing review petition.

Synopsis of the Judgment

The appellant, a member of the Border Security Force (BSF), was dismissed from service for contracting a second marriage without permission during the subsistence of his first marriage. His dismissal order was issued at Narayanpur, West Bengal. His statutory petition under Rule 28A of the BSF Rules was rejected by the Inspector General at Jammu. He filed a writ petition before the Delhi High Court, contending that the offices of the Director General, BSF and the Ministry of Home Affairs are located in Delhi, conferring territorial jurisdiction under Article 226(1). The Delhi High Court dismissed the petition applying the doctrine of forum non conveniens, holding that the cause of action arose in West Bengal and Jammu & Kashmir, and that Delhi was not a convenient forum. The Supreme Court allowed the appeal, holding that: (i) under Article 226(1), the Delhi High Court had territorial jurisdiction because the Director General, BSF (the authority vested with supervision and command) is situated in Delhi; (ii) the doctrine of forum non conveniens cannot be applied to defeat a litigant’s right to approach a High Court that has clear constitutional jurisdiction under Article 226(1), especially when the respondent is the Union of India and the authority whose order is challenged is amenable to suit at Delhi; (iii) the principle in Abrar Ali v. CISF was correctly decided; (iv) the Division Bench misapplied the doctrine as it is ordinarily invoked when multiple alternative fora exist and the chosen forum is oppressive or vexatious, but here the appellant had a constitutional right to sue where the respondent sits. The impugned order was set aside, and the writ petition was ordered to be restored before the Delhi High Court for hearing on merits.

1. Basic Information of the Judgment

Case Title: Baksish Ahmad v. Union of India and Another

Citation: 2026 INSC 630

Civil Appeal Nos.: Arising out of SLP (Civil) Nos. 855-856 of 2026

Bench: Justice Dipankar Datta & Justice Satish Chandra Sharma

Date of Decision: June 9, 2026

Court: Supreme Court of India (Civil Appellate Jurisdiction)

Impugned Order: Judgment and order dated 10th January 2025 of the High Court of Delhi at New Delhi in Writ Petition (C) No. [not specified] and order dated 29th August 2025 dismissing the review petition.

2. Legal Framework

Major Laws and Provisions Involved

• Constitution of India, 1950 – Article 226(1) (power of High Courts to issue writs where the person or authority against whom the writ is sought is situated within the territorial limits of the High Court), Article 226(2) (power where the cause of action arises wholly or in part within the territorial limits).

• Border Security Force Act, 1968 – Sections 4 and 5 (command and administration of BSF vest in the Director General).

• Border Security Force Rules, 1969 – Rule 7 (misconduct), Rule 22 (dismissal or removal by Commandant), Rule 22(4) (every order of dismissal to be communicated to the Director General), Rule 177 (procedure for imposing major penalties), Rule 28A (statutory petition against dismissal).

• Central Civil Services (Conduct) Rules, 1964 – Rule 21 (restriction regarding marriage).

• Doctrine of forum non conveniens – A court having jurisdiction may decline to exercise it if there is a more appropriate forum available, provided the alternative forum can provide fair and adequate remedy.

Key Precedents Cited and Applied

• Abrar Ali v. CISF (2012) 12 SCC 152 – Delhi High Court has territorial jurisdiction under Article 226(1) where the headquarters of the CAPF (CISF) is located in Delhi; the High Court overlooked clause (1) and erroneously dismissed on ground of no cause of action.

• Shri Ranjeet Mal v. General Manager, Northern Railway, Baroda House, New Delhi (1977) 1 SCC 484 (Three-Judge Bench) – Union of India would be fastened with liability for enforcement of an order quashing dismissal, and the Union of India has its seat at Delhi; therefore, the Delhi High Court had jurisdiction.

• Kusum Ingots & Alloys Ltd. v. Union of India (2004) 6 SCC 254 (Three-Judge Bench) – Even if a small part of cause of action arises within territorial jurisdiction, the High Court may refuse to exercise discretion by invoking the doctrine of forum conveniens (not forum non conveniens in that context).

• Arif Azim Co. Ltd. v. Micromax Informatics FZE (2023) 13 SCC 130 (Three-Judge Bench) – Doctrine of forum non conveniens applies where multiple fora are available; the court may decline jurisdiction if another forum is more convenient and fair. Factors include private and public interest.

• Eastern Coalfields Ltd. v. Kalyan Banerjee (2008) 11 SCC 466 – Head office location alone does not confer jurisdiction when the head office had nothing to do with the order of punishment.

• Dinesh Chandra Gahtori v. Chief of Army Staff (2001) 9 SCC 525 – Chief of Army Staff can be sued anywhere in the country. (Distinguished as pre-Armed Forces Tribunal Act and not applicable to CAPF post-AFT).

3. Relevant Facts

The appellant was enrolled as a member of the Border Security Force (BSF) on 31st December 2010 and was posted in the 44th Battalion at Narayanpur, Malda, West Bengal. In April 2022, a missing person report concerning a lady was received. The appellant and another constable were suspected of abduction. Simultaneously, the appellant’s first wife lodged a complaint alleging that the appellant had contracted a second marriage with the lady against her wishes and had subjected her to criminal force.

A Staff Court of Inquiry (SCoI) was ordered. The inquiry found that the appellant had married the lady (who herself was married) on 6th May 2022 during the subsistence of his first marriage, without obtaining necessary permission from the competent authority and without divorcing his first wife. The marriage was registered under the Uttar Pradesh Marriage Registration Rules, 2017 on 23rd May 2022 at Kushinagar, Uttar Pradesh. The SCoI exonerated him of abduction allegations.

On 19th September 2022, the appellant was served with a show cause notice under Rules 22 and 177 of the BSF Rules, alleging violation of Rule 7 of the BSF Rules and Rule 21 of the CCS (Conduct) Rules, 1964. He failed to reply within the stipulated fifteen days.

On 27th October 2022, the Commandant, 44th Battalion, passed an order dismissing the appellant from service without pensionary benefits. The order was served on him at Narayanpur, West Bengal.

The appellant filed a statutory petition under Rule 28A of the BSF Rules, which was placed before the Inspector General, Frontier Headquarters, BSF, Jammu, who condoned the delay but rejected the petition on merits on 22nd December 2023.

The appellant filed a writ petition before the Delhi High Court under Article 226. The Division Bench dismissed the petition applying the doctrine of forum non conveniens, holding that the cause of action arose in West Bengal (where dismissal order was issued) and in Jammu & Kashmir (where statutory petition was rejected), and that merely because the offices of the Director General, BSF and the Ministry of Home Affairs are situated in Delhi would not make Delhi the forum conveniens.

The appellant filed a review petition, which was also dismissed on 29th August 2025. He then appealed to the Supreme Court.

4. Issues

Issue No. 1: Whether the Delhi High Court had territorial jurisdiction under Article 226(1) of the Constitution to entertain the appellant’s writ petition, given that the Director General, BSF (the authority in whom command and administration of the BSF vests) and the Union of India have their offices in Delhi.

Issue No. 2: Whether the Delhi High Court was justified in applying the doctrine of forum non conveniens to decline to exercise its writ jurisdiction, when the appellant had a constitutional right to approach that court under Article 226(1).

Issue No. 3: Whether the decision in Abrar Ali v. CISF was correctly decided and applies to the present case.

Issue No. 4: Whether the impugned order should be set aside and the writ petition restored before the Delhi High Court for hearing on merits.

5. Ratio Decidendi

A. The Delhi High Court had territorial jurisdiction under Article 226(1) (Paras 27, 35-40).

The Court held that Article 226(1) confers jurisdiction on a High Court where the person or authority against whom the writ is sought is situated within its territorial limits. In the present case, the orders of dismissal were passed by the Commandant, 44th Battalion, but under Rule 22(4) of the BSF Rules, every order of dismissal must be communicated to the Director General, BSF. The Director General is the head of the force, in whom command and administration of the BSF vest (Sections 4 and 5 of the BSF Act). The Director General’s office is located in Delhi. Moreover, the Union of India, which is ultimately responsible for the enforcement of any order quashing the dismissal, has its seat in Delhi. Relying on the three-Judge Bench decision in Shri Ranjeet Mal v. General Manager, Northern Railway, the Court held that the Union of India can be sued at Delhi. Therefore, the Delhi High Court had clear territorial jurisdiction under Article 226(1).

B. The decision in Abrar Ali (supra) was correctly decided and applies (Paras 17-21, 27).

The Court examined the order under challenge in Abrar Ali and the decision of this Court therein. While noting that the observation that the Delhi High Court had overlooked clause (1) of Article 226 might not have been wholly accurate (since the Delhi High Court had considered it), the Court nevertheless agreed with the conclusion in Abrar Ali that the Delhi High Court has jurisdiction when the headquarters of the CAPF (CISF) is located in Delhi. The Court affirmed that for members of the Central Armed Police Forces (CAPF), including BSF, the Delhi High Court has territorial jurisdiction under Article 226(1) based on the situs of the office of the Director General and the Union of India.

C. The doctrine of forum non conveniens was misapplied in the context of Article 226(1) jurisdiction (Paras 28-40).

The Court distinguished Arif Azim (which arose from commercial arbitration, not writ jurisdiction). It noted that the doctrine of forum non conveniens applies only where multiple alternate fora are available, and the chosen forum is oppressive or vexatious, or where there is a more convenient forum. However, in the present case, the appellant had approached the Delhi High Court not merely based on cause of action but based on the situs of the respondent under Article 226(1). The Court held that the doctrine of forum non conveniens cannot be invoked to defeat a litigant’s constitutional right to approach a High Court that has jurisdiction under Article 226(1). The Division Bench had erred in applying the doctrine because the appellant had a perfectly valid and convenient forum in Delhi. The Court emphasized that the appellant, a dismissed BSF constable, could not be expected to file his writ petition in West Bengal or Jammu & Kashmir, which are far from his residence in Uttar Pradesh, whereas Delhi is centrally located and accessible. Moreover, the respondents (Union of India and Director General, BSF) are based in Delhi, making Delhi a convenient forum for them as well.

D. The alternative fora are not “more convenient” than Delhi; the Division Bench’s approach was erroneous (Paras 33-40).

The Court identified three alternative fora based on part cause of action: (i) Calcutta High Court (where dismissal order issued), (ii) Jammu & Kashmir High Court (where statutory petition rejected), and (iii) Allahabad High Court (where the marriage was registered). However, the Court held that the existence of multiple fora does not obligate the litigant to choose a particular one. The litigant has the right to choose any court having jurisdiction. The Delhi High Court’s refusal to entertain the petition on the ground that other courts were more convenient was an improper exercise of discretion. The Court observed that the appellant had already suffered significant delay, and relegating him to another High Court would cause further hardship. The interests of justice required that the Delhi High Court hear the writ petition on merits.

E. The impugned order set aside; writ petition restored (Paras 40-41).

The Supreme Court set aside the impugned judgment of the Division Bench and the order dismissing the review petition. The writ petition was ordered to be restored before the Delhi High Court for hearing on merits.

6. New Legal Principles Established / Reiterated

• For members of the Central Armed Police Forces (CAPF), including the Border Security Force (BSF), the Central Industrial Security Force (CISF), etc., the Delhi High Court has territorial jurisdiction under Article 226(1) of the Constitution because the Director General of the concerned force (the authority in whom command and administration vests) and the Union of India are situated in Delhi. This is a clear constitutional jurisdiction independent of where the cause of action arose.

• The doctrine of forum non conveniens, which is ordinarily applied in private international law or commercial disputes involving multiple cross‑border jurisdictions, cannot be invoked to decline writ jurisdiction under Article 226(1) where the High Court has clear territorial jurisdiction based on the situs of the respondent. The doctrine may have limited application in writ proceedings where the court has concurrent jurisdiction with another High Court based on cause of action, but it cannot be used to defeat a litigant’s constitutional right to sue where the respondent sits.

• The decision in Abrar Ali v. CISF is affirmed: the Delhi High Court cannot dismiss a writ petition by a CAPF member on the ground of lack of territorial jurisdiction when the headquarters of the force is located in Delhi. Even if the High Court perceives other High Courts as more convenient, it must exercise its discretion judiciously and not abdicate its jurisdiction.

• In service matters involving paramilitary forces, the High Court within whose territorial jurisdiction the disciplinary authority issued the order or the appellate authority rejected the appeal has jurisdiction under Article 226(2). However, the High Court within whose jurisdiction the superior authority (Director General) is situated also has jurisdiction under Article 226(1). The existence of multiple fora does not make any one forum inconvenient per se.

7. Court’s Examination and Analysis

The Court began by setting out the factual background and the appellant’s contention that the Delhi High Court had jurisdiction under Article 226(1). It noted that the Division Bench did not dismiss the petition for lack of jurisdiction but applied the doctrine of forum non conveniens.

The Court then examined the decision in Abrar Ali. It reproduced the order of the Delhi High Court in that case and the Supreme Court’s order. The Court observed that although the observation that the Delhi High Court overlooked clause (1) of Article 226 might have been an oversimplification, the ultimate conclusion that the Delhi High Court had jurisdiction was correct. The Court agreed with the reasoning that the headquarters of the CAPF is situated in Delhi, and therefore the High Court at Delhi is competent to entertain writ petitions from members of that force.

The Court then considered the doctrine of forum non conveniens. It traced the doctrine from Arif Azim and other cases. It noted that the doctrine is typically invoked in cross‑border disputes where multiple national courts have jurisdiction. In the context of writ jurisdiction under Article 226, the doctrine has a limited role – it may be applied when a litigant chooses a forum that is oppressive or vexatious, or when there is a more appropriate forum that can provide a similar remedy. However, the Court held that the doctrine cannot be used to deny a litigant access to a court that has constitutional jurisdiction under Article 226(1) based solely on the situs of the respondent.

The Court distinguished Kusum Ingots where this Court observed that even if a small part of cause of action arises, the High Court may refuse to exercise discretion by invoking the doctrine of forum conveniens (i.e., it may decline to entertain if the matter is more appropriately heard elsewhere). However, in Kusum Ingots, the jurisdiction was invoked under Article 226(2) based on cause of action, not under Article 226(1) based on the situs of the respondent. Here, the appellant invoked both clauses, but the primary basis was clause (1). The Court held that where the respondent is situated within the territorial limits of a High Court, that High Court cannot refuse to entertain the writ petition on the ground of forum non conveniens, because the Constitution itself confers jurisdiction.

The Court also noted practical considerations: the appellant’s residence was in Uttar Pradesh; West Bengal and Jammu & Kashmir were far away. Delhi was centrally located and accessible. The respondents were based in Delhi, so there was no inconvenience to them. The Division Bench’s reliance on forum non conveniens was therefore erroneous.

Finally, the Court set aside the impugned order and restored the writ petition. It directed the Delhi High Court to hear and decide the writ petition on merits.

8. Critical Analysis

Strengths: The judgment is a significant clarification of the territorial jurisdiction of High Courts under Article 226(1) in service matters involving Central Armed Police Forces. It correctly holds that the situs of the superior authority (Director General) confers jurisdiction on the Delhi High Court, regardless of where the cause of action arose. This prevents harassment of litigants who would otherwise have to travel to distant States to challenge disciplinary orders. The judgment also limits the misuse of the doctrine of forum non conveniens in writ proceedings. It recognises that the doctrine is not a panacea to decline jurisdiction when the Constitution clearly grants it. The Court’s reliance on Shri Ranjeet Mal (three-Judge Bench) and Abrar Ali is appropriate.

Potential concerns: The judgment does not explicitly overrule Eastern Coalfields Ltd. v. Kalyan Banerjee (where a similar contention was rejected), but it distinguishes it on the ground that in that case the head office had no role in the order of punishment. In the present case, the Director General had a statutory role (Rule 22(4) requires communication to the Director General, and he is the head of the force). The Court also noted that Kalyan Banerjee did not consider Shri Ranjeet Mal. The judgment could have clarified the interplay between Article 226(1) and Article 226(2) more comprehensively, but it is adequate.

Practical impact: This judgment will be cited in all writ petitions filed by members of CAPF (BSF, CISF, CRPF, ITBP, SSB, etc.) before the Delhi High Court. It will prevent High Courts from dismissing such petitions on the ground of lack of territorial jurisdiction or forum non conveniens. It will also have implications for other Central Government employees where the disciplinary authority is located outside Delhi but the Union of India or the administrative ministry is based in Delhi. However, the Court cautioned that this principle applies to cases where the superior authority has a role in the disciplinary process. Where the order of dismissal is purely by a subordinate authority and no appeal lies to a Delhi‑based authority, the position may be different.

9. Final Outcome

The Civil Appeal was allowed.

• The impugned judgment and order dated 10th January 2025 of the Division Bench of the Delhi High Court, as well as the order dated 29th August 2025 dismissing the review petition, were set aside.

• The writ petition (Writ Petition (C) No. [original number]) was ordered to be restored to the file of the Delhi High Court.

• The Delhi High Court was directed to hear and decide the writ petition on its merits in accordance with law.

• It was clarified that the observations made by the Supreme Court (including the reference to Abrar Ali) shall not be construed as an expression of opinion on the merits of the appellant’s case.

• No order as to costs.

• Pending applications stood disposed of.

10. Practical Application

For members of Central Armed Police Forces (CAPF) who are dismissed or penalised: You have the option to file a writ petition before the Delhi High Court under Article 226(1), because the Director General of your force and the Union of India have their offices in Delhi. You are not required to file the petition only where the cause of action arose (e.g., where the dismissal order was issued). However, you must ensure that the Director General or the Union of India is impleaded as a respondent. Also, you may still have the option to approach other High Courts where the cause of action arose (e.g., the High Court within whose jurisdiction the disciplinary authority is located). Choose the forum that is most convenient for you. After this judgment, the Delhi High Court cannot dismiss your petition on the ground of forum non conveniens.

For the Delhi High Court: When a member of a CAPF files a writ petition challenging a disciplinary order, and the petition is based on Article 226(1) (situs of the Director General or Union of India), you must entertain it on merits. You cannot decline jurisdiction on the ground that the cause of action arose elsewhere or that other High Courts are more convenient. However, you may still examine whether the petitioner has an effective alternative remedy under the BSF Rules or the Administrative Tribunals Act (if applicable). The forum non conveniens doctrine, as applied in Arif Azim, does not override the constitutional jurisdiction under Article 226(1).

For the Union of India and CAPF authorities: You cannot object to the territorial jurisdiction of the Delhi High Court when a writ petition is filed there challenging a disciplinary order, if the petitioner has impleaded the Director General or the Union of India. You may still raise other defences (e.g., alternative remedy, maintainability, merits), but the jurisdiction objection will not succeed. You should be prepared to defend the case in Delhi.

For lawyers representing CAPF members: When filing a writ petition before the Delhi High Court, clearly invoke both Article 226(1) and Article 226(2). State that the respondent (Union of India and the Director General) are situated in Delhi. Cite Abrar Ali and this judgment. If the court raises a question of territorial jurisdiction or forum non conveniens, rely on paragraph 35 of this judgment (the doctrine cannot be applied to defeat jurisdiction under Article 226(1)). Also cite Shri Ranjeet Mal for the proposition that the Union of India can be sued at Delhi.

For lawyers representing the Union of India or CAPF: After this judgment, you cannot successfully challenge the territorial jurisdiction of the Delhi High Court in such cases. Instead, focus on the merits or alternative remedies. However, you may argue that the petitioner has an effective alternative remedy before the Central Administrative Tribunal (CAT) if the service matter is covered by the Administrative Tribunals Act, 1985. But note that the Delhi High Court has concurrent jurisdiction with CAT in service matters, and the doctrine of forum non conveniens does not apply to choose between the High Court and CAT – the litigant has the right to choose.

For courts (High Courts): Before applying the doctrine of forum non conveniens in writ proceedings, examine the basis of jurisdiction. If the jurisdiction is under Article 226(1) based on the situs of the respondent, the doctrine should not be applied lightly. If the jurisdiction is under Article 226(2) based on cause of action, and there are multiple High Courts where part of the cause of action arose, you may still consider the doctrine, but you must exercise discretion judiciously. The convenience of the litigant and the respondent, the location of evidence, and the ends of justice must be weighed. Merely because another court also has jurisdiction is not a ground to decline.

11.  Court Lines

Line 1 (Jurisdiction under Article 226(1) – Para 27):
“... we hold that in case any member of the CAPF, and that includes the BSF, is aggrieved by any administrative order of termination of his service issued by the competent authority, notwithstanding that the cause of action arose outside, i.e., the said order was issued from a place beyond the territorial limits of the Delhi High Court or that the events which triggered such an order occurred outside its limits, etc., still the Delhi High Court would have territorial jurisdiction in light of situs of office of the Union of India and the Director General, BSF/the officer in whom is vested supervision and command of the other CAPF, as per clause (1) of Article 226.”

Line 2 (Forum non conveniens misapplied – Para 35):
“In our considered opinion, the doctrine of forum non conveniens has been misapplied by the Division Bench in the context of writ jurisdiction under Article 226 of the Constitution. Once it is found that a High Court has territorial jurisdiction to entertain a writ petition under Article 226(1) of the Constitution, it would be improper for such court to decline the exercise of its discretion on the ground that there exists other more convenient forums. The doctrine of forum non conveniens cannot be permitted to defeat the constitutional right of a litigant to approach a High Court which has jurisdiction under Article 226(1).”

Line 3 (Abrar Ali affirmed – Para 27):
“Notwithstanding that the appellant could have approached any of the three high courts based on accrual of part cause of action, as observed earlier, the Delhi High Court is indeed the fourth forum which had the competence to entertain and try the writ petition of the appellant.”

Line 4 (Burden and discretion – Para 39):
“While it is true that the choice of forum by the litigant is not decisive, and the court has the discretion to decline jurisdiction, such discretion must be exercised judiciously and not arbitrarily. In the facts of the present case, the Division Bench failed to exercise its discretion judiciously. The appellant, a dismissed constable of the BSF, cannot be expected to travel to West Bengal or Jammu and Kashmir to seek justice when the respondents are based in Delhi and the Director General, BSF is located there. The ends of justice would be better served if the writ petition is heard and decided by the Delhi High Court.”

Line 5 (Restoration – Para 40):
“Consequently, the appeal is allowed. The impugned order of the Division Bench of the Delhi High Court dated 10th January 2025, as well as the order dated 29th August 2025 dismissing the review petition, are set aside. The writ petition filed by the appellant stands restored to the file of the Delhi High Court for consideration on merits in accordance with law.”

12. Legal Strategy Insight

For a member of CAPF (BSF, CISF, CRPF, etc.) challenging dismissal: File your writ petition before the Delhi High Court. In the petition, specifically plead that the Director General of the force (whose office is in Delhi) is the authority in whom command and administration vests, and that the Union of India also has its seat in Delhi. Invoke Article 226(1) as the basis of jurisdiction. Do not rely solely on cause of action under Article 226(2). If the Delhi High Court raises an objection of forum non conveniens, cite this judgment and Abrar Ali. Also argue that the alternative High Courts (where cause of action arose) are far away and would cause hardship. The Delhi High Court cannot refuse to entertain your petition.

For a CAPF member who chooses to file in another High Court (e.g., where the dismissal order was issued): You may also file there under Article 226(2). But be aware that the Delhi High Court is also available as an option. Choose the forum that is most convenient for you. If you file in a distant High Court, the respondent may raise an objection that the Delhi High Court is more convenient? That is unlikely because the respondent would prefer Delhi where they are based. But you have the right to choose.

For a lawyer representing the Union of India or CAPF: If a writ petition is filed before the Delhi High Court, you cannot challenge jurisdiction. Instead, argue on merits or on alternative remedy (e.g., the petitioner could have approached the Central Administrative Tribunal, but note that the High Court has concurrent jurisdiction). Do not waste time on jurisdictional objections; they will be overruled.

For a High Court judge considering a writ petition by a CAPF member: First, verify whether the petitioner has impleaded the Director General or the Union of India. If yes, the Delhi High Court has jurisdiction under Article 226(1). Do not dismiss on forum non conveniens. If the petitioner has also invoked Article 226(2) and there are multiple possible High Courts, you may still exercise discretion, but you must weigh the convenience of the parties. If the petitioner is based in a distant State and the respondents are in Delhi, it may be more convenient for the petitioner to approach the Delhi High Court (since the respondents are there). In any event, do not dismiss summarily; hear the matter on merits or transfer it to an appropriate court if truly inconvenient for both parties.

For a CAPF member who has already filed a writ petition in a High Court other than Delhi and it is pending: You may consider filing a fresh petition in Delhi, but be mindful of limitation and res judicata. If your petition is pending elsewhere, you may seek transfer to Delhi under Article 139A or Section 25 of the CPC, but that is discretionary. Alternatively, continue in the chosen forum. This judgment does not compel you to file in Delhi; it only confirms that Delhi is a valid forum.

For a litigant in a service matter involving a Central Government employee (not CAPF): If the disciplinary authority is located outside Delhi but the Union of India is impleaded, does the Delhi High Court have jurisdiction? This judgment dealt specifically with CAPF where the Director General has statutory command. For ordinary Central Government employees, the position may be different. The decision in Shri Ranjeet Mal (railway employee) held that the Union of India can be sued at Delhi, but subsequent decisions have taken a nuanced view. You should examine the specific facts. The safest approach is to file where the cause of action arose, or where the appellate/revisional authority (if located in Delhi) passed an order. If no part of cause of action arose in Delhi, merely impleading the Union of India may not confer jurisdiction, as held in Eastern Coalfields. This judgment does not overrule that; it is confined to CAPF where the Director General has a direct role.