Territorial jurisdiction under Article 226 turns on the final operative order, not the earlier local refusal.

Territorial jurisdiction under Article 226 is limited by the location and amenability of the authority against whom effective relief is sought. Where the final operative order is made by a central authority outside the High Court's territorial reach, relief cannot be granted against the local antecedent order alone if the later outside order remains outstanding. Under the Mineral Concession Rules, 1949, the Central Government's review order was the final and effective determination, and the State Government's earlier refusal did not survive independently. The result was that the writ court had no territorial jurisdiction to quash the final order, and the statutory scheme made the Central Government's decision conclusive.

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Issues: (i) Whether the Orissa High Court had territorial jurisdiction under Article 226 of the Constitution of India to issue a writ when the final rejection of the mining-lease application was made by the Central Government outside its territorial limits; (ii) whether the State Government's order could be treated as the effective order notwithstanding the Central Government's rejection in review under the Mineral Concession Rules, 1949.

Issue (i): Whether the Orissa High Court had territorial jurisdiction under Article 226 of the Constitution of India to issue a writ when the final rejection of the mining-lease application was made by the Central Government outside its territorial limits.

Analysis: The power under Article 226 is territorially limited both by the territorial reach of the writ and by the location or amenability of the authority against whom relief is sought. Where the operative and final order is made by an authority situated outside the High Court's jurisdiction, a writ against the local authority would not afford effective relief if the outside order remains outstanding. On the facts, the Central Government's rejection of the review petition was the final operative order and the Central Government was not within the Orissa High Court's territorial jurisdiction.

Conclusion: The Orissa High Court had no jurisdiction to grant relief under Article 226 against the final order of the Central Government.

Issue (ii): Whether the State Government's order could be treated as the effective order notwithstanding the Central Government's rejection in review under the Mineral Concession Rules, 1949.

Analysis: Under the Mineral Concession Rules, 1949, the review mechanism placed the matter before the Central Government, and the Central Government's order under the review provisions was declared final by Rule 60. Once the review was decided, the State Government's earlier refusal could not survive as the operative determination. The Court distinguished cases where a departmental order continued to operate on its own strength and held that, in this statutory scheme, the Central Government's order prevailed and confirmed the rejection of the application.

Conclusion: The Central Government's order in review was the effective and final order, and the State Government's order did not remain independently operative.

Final Conclusion: The appeal failed because the decisive order was that of the Central Government, beyond the High Court's territorial reach, and the statutory scheme made that order final.

Ratio Decidendi: Where a statute makes the superior authority's decision in review final, that decision becomes the operative order for the purpose of Article 226, and a writ court lacking territorial jurisdiction over that authority cannot grant effective relief against the local antecedent order alone.

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