Territorial jurisdiction under Article 226 turns on cause of action; mere service of notice does not confer forum access.

Territorial jurisdiction under Article 226(2) depends on whether the cause of action, wholly or in part, arises within the court's territory. Mere service of an impugned notice within the forum State does not by itself confer jurisdiction unless that service is an integral part of the cause of action. Applying the settled test that cause of action is the bundle of facts needed to obtain relief, the Court noted that the substantive events arose outside the forum and the notices and clarification were issued elsewhere. On that basis, service within the State created no territorial nexus, and the writ petitions were dismissed for want of jurisdiction.

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Issues: Whether the High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain writ petitions when the impugned notices and clarification were issued outside its territory but served on the petitioners within its territory.

Analysis: Territorial jurisdiction under Article 226(2) depends on whether the cause of action, wholly or in part, arises within the territorial limits of the Court. The mere service of a notice is not enough unless that service forms an integral part of the cause of action. The Court applied the settled principle that cause of action means the bundle of facts which must be proved to obtain relief, and examined whether the notices served at Amritsar constituted such a part. Since the material events leading to the notices occurred at Mumbai and the impugned clarification and notices were issued at Delhi, the service of notices at Amritsar did not create a territorial nexus for this Court.

Conclusion: The High Court lacked territorial jurisdiction to entertain the writ petitions; the preliminary objection was upheld and the petitions were dismissed.

Ratio Decidendi: For jurisdiction under Article 226(2), the pleaded facts must show that the territorial event relied upon is an integral part of the cause of action; mere service of an impugned notice within the forum State does not confer jurisdiction when the substantive events and the impugned action arose elsewhere.

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