I've always been told that TODA* = TORA† + Clearway. I can't really imagine what a negative clearway would be, so that leads me to think that it is required that TODA >= TORA. Interestingly, a colleague pointed out a certain airport (Invercargill, New Zealand - ICAO code NZNV) where the declared distances published by a certain source describe a TODA that is in fact less than the TORA.
My colleague and I are under the impression that some kind of typographical error has occurred when this source was publishing the data. However, I can't help but think back to strikingly similar conversations we had after seeing a previously unheard of case where ASDA‡ < TORA. As it turned out, the FAA had changed how Runway Safety Areas were considered, in such a way that it is totally possible for ASDA < TORA (and we've been seeing it more and more frequently ever since).
*TODA = Take-Off Distance Available
†TORA = Take-Off Run Available
‡ASDA = Accelerate-Stop Distance Available
TL;DR
I wanted to see if anyone has ever heard of any other case where TODA < TORA, under any regulatory agency. What would the rationale be if that were the case?