Special statute jurisdiction overrides general civil procedure rules where company forum depends on the registered office location.

A special statute governing company matters fixes territorial jurisdiction by reference to the company's registered office, unless jurisdiction has been conferred on a local court by notification under that Act. In the absence of any pleaded notification conferring jurisdiction on the Ramachandrapuram court, the general territorial rules in the Code of Civil Procedure could not validate that forum. The pleaded cause of action also did not arise at Ramachandrapuram. The legal point is that where a special enactment prescribes the forum, the special jurisdictional scheme prevails over sections 9 and 20 of the Code of Civil Procedure.

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Issues: Whether the Subordinate Judge at Ramachandrapuram had territorial jurisdiction to entertain the suit and pass the order appointing an Advocate-Commissioner in view of the Companies Act and the Code of Civil Procedure.

Analysis: Jurisdiction in civil matters depends on subject-matter, pecuniary limits and territorial limits. The Companies Act is a special enactment, and for matters governed by it, jurisdiction turns on the place where the company's registered office is situate, unless jurisdiction has been conferred on a District Court by notification under the Act. The plaint did not show any such notification conferring jurisdiction on the Ramachandrapuram court. The plea based on sections 9 and 20 of the Code of Civil Procedure did not avail the respondent, because the alleged cause of action, on the pleadings, did not arise within Ramachandrapuram and, in any event, the relevant forum under the Companies Act remained the court having jurisdiction over the registered office at Madras.

Conclusion: The Sub-Court at Ramachandrapuram had no jurisdiction to entertain the suit, and the order appointing the Advocate-Commissioner was liable to be set aside.

Ratio Decidendi: Where a special statute fixes jurisdiction with reference to the company's registered office and jurisdiction is not shown to have been conferred on a local court by notification, the general territorial rules in the Code of Civil Procedure cannot confer jurisdiction on that court.

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