Forum non conveniens under Article 226 has a limited role when multiple High Courts can hear the writ petition.

Where a writ petition is maintainable in more than one High Court on different jurisdictional bases, the doctrine of forum non conveniens has only a limited role and must be used sparingly. Jurisdiction under Article 226 arising from the respondents' office location cannot be declined merely because another forum is also available, especially where the relevant records ordinarily remain with the respondents. In a challenge to dismissal from BSF service, the convenience of the respondents was not a valid ground to refuse entertainment of the petition. The Delhi High Court's refusal to exercise jurisdiction on forum non conveniens was therefore unsustainable, and the writ petition was required to be heard on merits.

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Issues: Whether the Delhi High Court was justified in declining to entertain the writ petition on the ground of forum non conveniens despite the respondents' offices being situated in Delhi and the Court having jurisdiction under Article 226.

Analysis: The writ petition could be maintained before more than one High Court on different jurisdictional bases. Where jurisdiction is attracted under Article 226 by reason of the situs of the respondents' office, the doctrine of forum non conveniens has a limited role and should be applied sparingly. In a challenge to dismissal from BSF service, the relevant records would ordinarily be available with the respondents, and the choice of a forum convenient to the respondents cannot be treated as self-defeating. The Delhi High Court, therefore, ought not to have declined to entertain the petition merely because other fora were also available.

Conclusion: The refusal to exercise jurisdiction on the ground of forum non conveniens was unsustainable and the writ petition ought to be heard on merits.

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