Territorial jurisdiction under Article 226 turns on cause of action, not merely the location of Parliament or the Legislature.

Territorial jurisdiction under Article 226 depends on whether a material part of the cause of action arises within the High Court's territory, not on the mere situs of Parliament, a State Legislature, or the place where an enactment is made. Cause of action means the material facts that must be pleaded and proved, and the same approach applies in writ proceedings as under Section 20(c) CPC. Mere service of notice, the place of business, or the location of the law-making authority does not by itself confer jurisdiction. Jurisdiction may arise only where implementation of the law or another legally relevant event creates civil consequences within the forum, and forum conveniens may also justify refusal.

---

---

Issues: Whether the situs of Parliament or the State Legislature, by itself, confers territorial jurisdiction on a High Court under Article 226 of the Constitution of India, and whether a writ petition challenging the constitutionality of a parliamentary enactment can be entertained merely on that basis.

Analysis: Clause (2) of Article 226 extends jurisdiction to a High Court only where the cause of action, wholly or in part, arises within its territorial limits. The expression "cause of action" refers to the material facts which must be pleaded and proved, and the court must examine whether the facts asserted constitute integral facts giving rise to the dispute. The phraseology of Article 226(2) is in pari materia with Section 20(c) of the Code of Civil Procedure, 1908, and the principles governing territorial jurisdiction under that provision are applicable to writ proceedings. Mere service of notice, the place of business, or the situs of the authority making the law or issuing the notification does not by itself create a cause of action. A legislative act, even when it applies throughout India, does not by its mere enactment furnish a jurisdictional foundation to challenge it in every High Court. Territorial jurisdiction is attracted only when implementation of the law or another legally relevant event gives rise to civil consequences within the court's territory. The doctrine of forum conveniens may also justify refusal to exercise jurisdiction even where a small part of the cause of action arises within the forum.

Conclusion: The situs of Parliament or the Legislature is not, by itself, a relevant factor for territorial jurisdiction under Article 226. The High Court of Delhi lacked jurisdiction on the facts pleaded, and the appeal fails.

Ratio Decidendi: Territorial jurisdiction under Article 226(2) depends on the arising of a material part of the cause of action within the court's territory, and not merely on the location of the law-making authority or the place where the impugned legislation was enacted.

---