Territorial jurisdiction defect nullifies interim injunction and defeats later reliance on the vacated order.

An interim injunction granted by a court without territorial jurisdiction is a nullity and cannot support later relief once the jurisdictional defect is established. Where the Bombay court subsequently held that it lacked jurisdiction, vacated the ad interim injunction, and dismissed the contempt application, the basis for the petitioner's claim to injunction disappeared. In the absence of waiver of the jurisdictional objection, the earlier order could not remain operative, and events occurring in the meantime could not be treated as illegal on that footing. The petitioner was therefore not entitled to injunction, and the revision failed.

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Issues: Whether the petitioner was entitled to injunction on the basis of an ad interim injunction passed by another court, after that court was found to lack territorial jurisdiction and had vacated the injunction.

Analysis: The dispute turned on the effect of an order made by a court lacking territorial jurisdiction. An order passed without jurisdiction is a nullity and its invalidity can be raised even in collateral proceedings. Since the Bombay court later held that it had no jurisdiction to entertain the suit, vacated the ad interim injunction, and dismissed the contempt application, the foundation on which the petitioner sought relief disappeared. The record also showed no waiver of the jurisdictional objection by the respondent. The later order did not leave the earlier injunction operative, and the meeting held in the meantime could not be treated as illegal on that basis.

Conclusion: The petitioner was not entitled to the injunction and the revision failed.

Ratio Decidendi: An interim order issued by a court that ultimately lacks territorial jurisdiction is inoperative as a nullity, and no injunction can be sustained on the basis of such an order once its jurisdictional defect is established and the order is vacated.

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