Territorial jurisdiction under Article 226 requires an integral cause of action within the court's territory; incidental facts are insufficient.

Territorial jurisdiction under Article 226 depends on whether the pleaded facts show that the cause of action, wholly or in part, arose within the High Court's territory. The Court held that incidental or remote facts, such as reading an advertisement, filing a tender, sending correspondence, or receiving a fax at one location, do not by themselves form an integral part of the cause of action where the tender was to be scrutinised and rejected elsewhere. On the facts stated, no part of the cause of action arose within the Calcutta High Court's jurisdiction, so the writ petition there was not maintainable.

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Issues: Whether any part of the cause of action arose within the territorial jurisdiction of the Calcutta High Court so as to sustain the writ petition under Article 226 of the Constitution of India.

Analysis: Territorial jurisdiction under Article 226 depends on whether the facts pleaded disclose that the cause of action, wholly or in part, arose within the High Court's territory. The expression "cause of action" means the bundle of material facts that the petitioner must prove to obtain relief. Facts such as reading the advertisement in Calcutta, submitting the tender from Calcutta, sending representations from Calcutta, and receiving a fax reply there did not constitute an integral part of the cause of action, because the tender was to be received and scrutinised at New Delhi and the final decision was taken there. The rejection of the offer occurred at New Delhi, and the location of the petitioner's office or its correspondence from Calcutta was insufficient to found jurisdiction.

Conclusion: No part of the cause of action arose within the jurisdiction of the Calcutta High Court, and the writ petition was not maintainable there.

Final Conclusion: The High Court lacked territorial jurisdiction and its order was set aside, with the writ petition disposed of for want of jurisdiction and exemplary costs imposed for the abuse of jurisdiction.

Ratio Decidendi: Facts that are merely incidental, remote, or unconnected with the substantive grievance do not constitute an integral part of the cause of action for the purpose of Article 226(2) territorial jurisdiction.

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