Synopsis

The petitioner, a registered insolvency professional based in Kolkata, challenged a show cause notice and a two‑year suspension order issued by the Insolvency and Bankruptcy Board of India (IBBI), Delhi. The petitioner argued that since the impugned orders were issued from IBBI’s Delhi office, the Delhi High Court had territorial jurisdiction. The court dismissed the petition, holding that although a small part of the cause of action (the issuance of the order) arose in Delhi, the “dominant” and “integral” facts of the dispute related to the petitioner’s conduct as an insolvency professional in Kolkata (where the CIRP proceedings took place). Relying on Kusum Ingots and Indure Pvt. Ltd., the court invoked the doctrine of forum conveniens and relegated the petitioner to the jurisdictional High Court (Calcutta).

Court: High Court of Delhi
Coram: Purushaindra Kumar Kaurav, J.
Date: March 30, 2026
Citation: 2026:DHC:2792
Core Law: Constitutional Law (Article 226 – Territorial Jurisdiction), Insolvency and Bankruptcy Code, 2016; Doctrine of Forum Conveniens.

2. Legal Framework

• Constitution of India: Article 226 – territorial jurisdiction of High Courts; discretionary nature of writ remedy.

• Insolvency and Bankruptcy Code, 2016: Sections 218, 220 – powers of IBBI; disciplinary proceedings against insolvency professionals.

• IBBI (Inspection and Investigation) Regulations, 2017: Regulation 10A (challenged but not decided on merits due to jurisdiction).

• Doctrine of Forum Conveniens: Even where a part of cause of action arises, the court may refuse to exercise jurisdiction if a more convenient forum exists.

• Relevant Precedents:
  Kusum Ingots & Alloys Ltd. v. Union of India (

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