Territorial jurisdiction under Article 226 depends on where the cause of action arises, not merely where the employer's head office is located.

For Article 226 territorial jurisdiction, "cause of action" means the bundle of material facts that must be proved to obtain relief, and only facts with a real nexus to the prayer can confer jurisdiction. The mere location of an employer's head office in a State does not, by itself, create jurisdiction if no part of the cause of action arose within that High Court's territory. Jurisdiction lies only where the cause of action, in whole or in part, actually arises. On these principles, the Calcutta High Court lacked territorial jurisdiction to entertain the writ petition.

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Issues: Whether the Calcutta High Court had territorial jurisdiction to entertain the writ petition when the entire cause of action arose at Mugma in Jharkhand and the employer's head office was situated in West Bengal.

Analysis: For the purpose of Article 226, the expression "cause of action" carries the same meaning as in section 20(c) of the Code of Civil Procedure, namely the bundle of material facts that must be proved to obtain relief. Only facts having a real nexus with the prayer can confer jurisdiction. The situs of the employer's head office, by itself, does not create jurisdiction where no part of the cause of action has arisen within the territorial limits of the High Court. Jurisdiction exists only in the court where the cause of action, in whole or in part, actually arises.

Conclusion: The Calcutta High Court lacked territorial jurisdiction, and the writ petition could not be entertained there.

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