Territorial jurisdiction in writ proceedings depends on the real cause of action, not mere communication or branch presence.

Territorial jurisdiction depends on where the material cause of action arises, not on incidental communication or business presence. An order taking over management was made at Delhi, while the factory, registered office, and consequential possession and management were in Bihar; publication in the Official Gazette was only a condition for effectiveness and did not shift the place of making the order. Forwarding a copy to directors in Calcutta and the existence of branch or sales activity there were insufficient to confer jurisdiction. The writ petition was therefore not maintainable before the Calcutta High Court for want of territorial jurisdiction.

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Issues: Whether the writ petition was maintainable before the High Court on the ground that a part of the cause of action arose within its territorial jurisdiction.

Analysis: The impugned order for taking over the management of the industrial undertaking was made at Delhi, the factory and registered office were in Bihar, and the consequential possession and management were also situated and acted upon there. Publication of the order in the Official Gazette was necessary for the order to take effect, but such publication did not change the place where the order was made. The forwarding of a copy to directors at Calcutta and the existence of branch or sales activity there were held insufficient to create a territorial cause of action within the jurisdiction of the High Court.

Conclusion: The writ petition was not maintainable in the High Court for want of territorial jurisdiction, and the preliminary objection succeeded.

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