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Supreme Court of India 2024-04-16 dismissed

ARCADIA SHIPPING LTD vs TATA STEEL LIMITED AND OTHERS

Bench: 2 — Sanjiv Khanna, Dipankar Datta

In Brief

Bhushan Steel (later merged with Tata Steel) sued multiple defendants—including Arcadia Shipping Limited, a Mumbai-based shipper—in the Delhi High Court for non-payment of goods under a letter of credit. Arcadia argued the Delhi court lacked territorial jurisdiction since it was based in Mumbai and involved shipment from Mumbai. The Supreme Court held that because the supply order was placed in Delhi and payment was to be released there, a part of the cause of action arose in Delhi, conferring jurisdiction. The Court also ruled that the sale and shipment transactions were intrinsically interconnected through the bill of lading and could not be artificially separated. Under the Code of Civil Procedure, all defendants could be joined in a single suit where relief arises from a series of connected transactions. The appeal was dismissed, upholding the Delhi High Court's jurisdiction.

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Territorial Jurisdiction Code of Civil Procedure Joinder of Defendants Cause of Action International Commercial Transactions Bills of Lading Letter of Credit

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