Disposed¶25

Bhilai Engineering Corporation Limited v. Steel Authority of India Limited

Delhi HC19 Jan 2026W.P.(C)/4892/2025

Case brief

AI extract

What is this about?

Forum conveniens; territorial jurisdiction; part of cause of action; writ remedy discretionary; refusal to entertain writ petition; liberty to approach jurisdictional High Court; SAIL blacklisting order 19.03.2025; ban until 11.09.2026; Sinter Plant-II, Bokaro Steel Plant; earlier Jharkhand HC W.P.(C) No. 2503 of 2023 withdrawn; Kusum Ingots & Alloys Ltd. v. Union of India (2004) 6 SCC 254 relied on; Bhagat Singh Bugga; Madanlal Jalan; Bharat Coking Coal; S.S. Jain & Co.; New Horizons Ltd.; Delhi HC refuses forum shopping across High Courts for same contract.

What did the court decide?

Petition not entertained; petitioner granted liberty to approach the jurisdictional High Court. ¶25

Bhilai Engineering Corporation Limited Vs Steel Authority of India Limited — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Petition not entertained; petitioner granted liberty to approach the jurisdictional High Court.

¶25

Issue for consideration

Whether the Delhi High Court should entertain the writ petition challenging the blacklisting order when only a part of the cause of action (the respondent-Authority's registered office being in Delhi) arises within its territorial jurisdiction, or whether the petitioner should instead approach the jurisdictional High Court.

¶17

Court's answer

The mere fact that a small part of the cause of action (including the mere situs of the respondent's head office/registered office) arises within the territorial jurisdiction of the High Court is not by itself a determinative factor compelling the Court to assume jurisdiction; the writ remedy being inherently discretionary, the High Court may refuse to entertain a petition in appropriate cases, invoking the doctrine of forum conveniens (relying on Kusum Ingots & Alloys Ltd. v. Union of India and Anr.).

¶17

Ratio / Principle

There is no reason why the petitioner should be allowed to file a petition pertaining to the same contract in different High Courts.

¶24

Key takeaways

The Court finds no justification to entertain the instant petition and instead grants the petitioner liberty to approach the jurisdictional High Court.ratio¶24

Detailed headnote1 paragraphs

Delhi High Court (Purushaindra Kumar Kaurav, J.), W.P.(C) 4892/2025 (decided 19.01.2026): Bhilai Engineering Corporation Ltd. challenged SAIL's Blacklisting order dated 19.03.2025 banning it from all business dealings with SAIL's Plants, Units and Subsidiaries until 11.09.2026, concerning the Sinter Plant-II project at Bokaro Steel Plant, Jharkhand. Although a part of the cause of action arose in Delhi because SAIL's registered office is there, the Court held that a small part of the cause of action, or the mere situs of the head office, is not by itself determinative; the writ remedy is discretionary and the doctrine of forum conveniens applies, relying on Kusum Ingots & Alloys Ltd. v. Union of India and Anr., (2004) 6 SCC 254. Noting the petitioner had earlier pursued the same contract before the Jharkhand High Court (W.P.(C) No. 2503 of 2023, later withdrawn), the Court found no justification for parallel proceedings in different High Courts and disposed of the petition with liberty to approach the jurisdictional High Court.

¶1

$~64

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- W.P.(C) 4892/2025 & CM APPL. 22515/2025

¶4

BHILAI ENGINEERING CORPORATION LIMITED

¶5

.....Petitioner Through: Mr. Rishi Anand, Mr. Utkarsh Mishra and Ms. Deeksha Dubey, Advs.

¶6

versus

¶7

STEEL AUTHORITY OF INDIA LIMITED

.....Respondent

Through: None.

CORAM:

HON’BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 19.01.2026

¶12

The lis in the present writ petition emanates from the Impugned Blacklisting order dated 19.03.2025, whereby the respondent has banned the petitioner from all future business dealings with all its Plants, Units and Subsidiaries until 11.09.2026. The underlying project pertains to the installation of Sinter Plant-II at the Bokaro Steel Plant in the State of Jharkhand. The petitioner itself is situated in Chhattisgarh.

¶13

Further, it is a matter of record that the petitioner had earlier approached the Jharkhand High Court with respect to another Blacklisting Order dated 12.09.2024, in W.P.(C) No. 2503 of 2023 titled Bhilai Engineering Corporation Limited v. Steel Authority of India Limited , which arose from the same project. The Jharkhand High Court granted an

¶14

This is a digitally signed order.

¶15

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/01/2026 at 13:34:38

¶16

interim relief in favour of the petitioner herein and against the respondentAuthority, stating that no risk and cost shall be recovered from the petitioner with respect to the same project at Bokaro Steel Plant. However, later, the said petition was withdrawn upon the respondent passing the subsequent order.

¶17

Learned counsel appearing for the petitioner is correct in contending that a part of the cause of action has arisen within the jurisdiction of this Court, to the effect that the impugned order has been passed by the respondent- Authority, which has its registered office in Delhi. However, the same should not be the sole reason to entertain the petition by this Court. 4. Even if the mere situs of the head office is considered as a part of the bundle of facts constituting the cause of action, the mere fact that a small part of the cause of action arises within the territorial jurisdiction of this Court would not by itself be a determinative factor compelling the Court to assume jurisdiction. The writ remedy, being inherently a discretionary remedy, the High Court, may refuse to entertain a petition, in appropriate cases. Reliance may be placed on Kusum Ingots & Alloys Ltd. v. Union of India and Anr. ,¹ the material portion of which reads as under:

¶18

“Forum conveniens

¶19

30. We must, however, remind ourselves that even if a small part of cause of action arises within the territorial jurisdiction of the High Court, the same by itself may not be considered to be a determinative factor compelling the High Court to decide the matter on merit. In appropriate cases, the Court may refuse to exercise its discretionary jurisdiction by invoking the doctrine of forum conveniens. [See Bhagat Singh Bugga v. Dewan Jagbir Sawhney [AIR 1941 Cal 670 : ILR (1941) 1 Cal 490] , Madanlal Jalan v. Madanlal [(1945) 49 CWN 357 : AIR 1949 Cal 495] , Bharat Coking Coal Ltd. v. Jharia Talkies & Cold Storage (P) Ltd. [1997 CWN 122] , S.S. Jain & Co. v. Union of

¶20

1 (2004) 6 SCC 254.

¶21

This is a digitally signed order.

¶22

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/01/2026 at 13:34:38

¶23

India [(1994) 1 CHN 445] and New Horizons Ltd. v. Union of India [AIR 1994 Del 126] .]”

¶24

There is no reason as to why the petitioner should be allowed to file a petition pertaining to the same contract in different High Courts. In view thereof, the Court finds that there is no justification to entertain the instant petition and instead, the petitioner is granted liberty to approach the jurisdictional High Court.

¶25

Petition stands disposed of.

¶26

PURUSHAINDRA KUMAR KAURAV, J

¶27

JANUARY 19, 2026 P/MJ

¶28

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 30/01/2026 at 13:34:38

Bhilai Engineering Corporation Limited v. Steel Authority of India Limited

Case brief

What is this about?

What did the court decide?

Bhilai Engineering Corporation Limited v. Steel Authority of India Limited

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Cases cited

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Kushagra Sharma and Ors. Vs Union of India & Anr.

Vivek Mukherji Vs Union of India & Anr.

Sanjay Kumar Nigam Vs Union of India & Ors.

Sudhanshu Joshi Vs Union of India & Ors.

Kashmiri Vs DDA and Ors.

Gaurav Singh Vs State (N.C.T. of Delhi) & Ors.

M/S Kanhiya Lal Giani Ram Vs Agriculture Producre Marketing Committee & Ors.

Rajiv Jain Vs Union of India & Anr.

Vivek Mukherji Vs Union of India & Anr.

Mohammad Wasi through Spa Suman Patra Vs Central Adoption Resource Authority & Anr.

Ajay Kumar Vs Union of India & Anr.

Anju Dhankar Vs Govt. of NCT of Delhi & Ors.

Narender Kathuria Vs Gnct of Delhi & Ors.

Cpio, LIC of India Vs T Thanka Shanti