Anil Laxminarayan Biyani v. Union of India
The formal location of central authorities did not create Delhi territorial jurisdiction on these facts.
By CA Nikhil Gupta · Reviewed against the retained judgment 2026-09-26
The formal location of central authorities did not create Delhi territorial jurisdiction on these facts. Writ dismissed for want of territorial jurisdiction.
What happened
A former Future-group official challenged the SFIO investigation through a Delhi writ despite the transaction and investigative nexus lying in Mumbai.
Questions before the court
- Did a sufficient part of the cause of action arise in Delhi?
Why the court ruled this way
The formal location of central authorities did not create Delhi territorial jurisdiction on these facts.
Controlling point
The formal location of central authorities did not create Delhi territorial jurisdiction on these facts.
Order and next steps
Writ dismissed for want of territorial jurisdiction.
Practical implications
The operative result is case-specific: Writ dismissed for want of territorial jurisdiction. Apply it within the court’s stated limit: SFIO investigation merits and alternative forum remain open.
Limits of this ruling
- SFIO investigation merits and alternative forum remain open.
Law and judgment source
- Companies Act, 2013, section 212
- Constitution, article 226
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Source checked: 2026-09-26 · Judgment paragraphs: paragraphs 23–30 · Later case history: not verified. Verify appeals, stays and subsequent orders before reliance.
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