Territorial jurisdiction under Article 226 depends on pleaded cause of action, and the Bombay High Court could entertain the writ petition.

Territorial jurisdiction under Article 226 depends on whether the cause of action, in whole or in part, arises within the High Court's territorial limits, and that enquiry must be made from the pleadings rather than by testing their truth at the threshold. In criminal proceedings and investigation-related writs, the place of the operative facts and other material events is relevant, and the complaint alone is not necessarily determinative. On the pleaded facts, substantial events connected with the dispute were linked to Mumbai, so the Bombay High Court had jurisdiction to entertain the writ petition seeking quashing of the complaint and transfer of investigation. Its summary dismissal for want of jurisdiction was therefore unsustainable.

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Issues: Whether the Bombay High Court lacked territorial jurisdiction under Article 226 of the Constitution to entertain the writ petition seeking quashing of the complaint and transfer of investigation, merely because the complaint had been lodged at Shillong.

Analysis: Territorial jurisdiction under Article 226 depends on whether the cause of action, wholly or in part, arises within the territorial limits of the High Court. Cause of action means the bundle of material facts which the petitioner must prove to obtain relief, and the question has to be answered on the basis of the pleadings, not by examining their truth at the threshold. In matters involving criminal proceedings and investigation, the place where the relevant events occurred and where the operative facts giving rise to the complaint took place are material. The complaint was not the sole determinative fact; the writ petition also challenged the investigation and sought transfer of the matter to Mumbai, and the pleaded facts showed substantial events connected with the dispute at Mumbai.

Conclusion: The Bombay High Court did have jurisdiction to entertain the writ petition, and its summary dismissal on the ground of want of jurisdiction was unsustainable.

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