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Case Analysis Sai Kripa Eye And Children Hospital vs Quality Council of India & Anr 2026 DHC 2515

Synopsis

This judgment by the Delhi High Court dismisses a writ petition filed by a hospital located in Punjab challenging a communication from the National Accreditation Board for Hospitals and Healthcare Providers (NABH) regarding its non-empanelment with the Ex-Servicemen Contributory Health Scheme (ECHS). The court held that it lacked territorial jurisdiction to entertain the petition. While the respondents were located in Delhi and the impugned order was issued from Delhi, the court found that the "material, essential, and integral" cause of action arose entirely in Punjab, where the petitioner hospital is situated and where the effect of the order would be felt. Applying the doctrine of forum conveniens and following its own judgment in Indure Pvt. Ltd., the court dismissed the petition, granting liberty to the petitioner to approach the jurisdictional High Court.


1. Heading for the judgment

Citation: Sai Kripa Eye And Children Hospital v. Quality Council of India & Anr., W.P.(C) 3507/2026, decided on 18.03.2026 (Delhi High Court)
Coram: Hon'ble Mr. Justice Purushaindra Kumar Kaurav (Single Judge)
Core Law: Constitutional Law (Article 226 – Territorial Jurisdiction), Doctrine of Forum Conveniens.

Delhi High Court dismisses writ petition of Punjab hospital against NABH, holds that location of authority in Delhi alone does not confer jurisdiction when core cause of action lies elsewhere.


2. Legal framework

This judgment deals with the principles governing territorial jurisdiction of High Courts under Article 226 of the Constitution.


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