HC Declines Jurisdiction Over DRI Seizure of Imported Goods Warehoused in Tamil Nadu

HC Declines Jurisdiction Over DRI Seizure of Imported Goods Warehoused in Tamil Nadu

The petitioners, M/s RR Fashion, M/s Yashi Fashion and M/s SS Impex, imported PVC coated fabrics from a Chinese supplier through the Special Economic Zone (SEZ) in Tamil Nadu. The goods were warehoused in Tamil Nadu. The Directorate of Revenue Intelligence (DRI), Delhi conducted inspections, lifted samples in Chennai, and issued multiple seizure memos during May 2025. The seized samples were sent to CRCL, New Delhi for testing.

Aggrieved, the petitioners approached the Delhi High Court challenging the seizure memos as well as the CRCL test reports, contending that part of the cause of action arose in Delhi since the DRI headquarters and the testing laboratory were located there.

Main Issue: Whether the Delhi High Court had territorial jurisdiction to entertain writ petitions challenging seizure memos issued by DRI when the imports, storage, sampling and service of seizure memos took place in Tamil Nadu, merely because the DRI office and testing laboratory were located in Delhi.

HC’s Decision: The Delhi High Court dismissed the writ petitions, holding that it lacked territorial jurisdiction. The Court ruled that mere location of the DRI headquarters or the CRCL laboratory in Delhi does not constitute a sufficient cause of action. The imports were effected in Chennai, the goods were warehoused in Tamil Nadu, samples were lifted there, and the seizure memos were served upon petitioners located in Tamil Nadu.

The Court applied the doctrine of forum conveniens as laid down by the Full Bench in Sterling Agro Industries Ltd. andm held that the appropriate forum was the jurisdictional High Court in Tamil Nadu. Liberty was granted to the petitioners to approach the appropriate High Court or forum in accordance with law.

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