Territorial jurisdiction depends on where the cause of action arises, and the later procedural explanation does not displace that rule.

Territorial jurisdiction under clause 14 of the High Court (Amalgamation) Order, 1948 was held to depend on whether the cause of action arose wholly or partly within the notified Oudh areas, including where the impugned order was issued at Lucknow. The Court rejected any separate theory of jurisdiction divorced from the ordinary cause-of-action test and reaffirmed the earlier construction of clause 14. The Explanation to Section 141 of the Code of Civil Procedure, 1908 did not alter that interpretation or justify denying jurisdiction. The contrary view was found erroneous, and the jurisdictional ruling was set aside.

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Issues: (i) Whether the Lucknow Bench had territorial jurisdiction under Article 226 of the Constitution of India read with clause 14 of the High Court (Amalgamation) Order, 1948, where the impugned governmental order was issued at Lucknow and the cause of action arose partly within the Oudh area; (ii) whether the Explanation to Section 141 of the Code of Civil Procedure, 1908 altered the interpretation of clause 14 so as to displace the rule laid down earlier on jurisdiction.

Issue (i): Whether the Lucknow Bench had territorial jurisdiction under Article 226 of the Constitution of India read with clause 14 of the High Court (Amalgamation) Order, 1948, where the impugned governmental order was issued at Lucknow and the cause of action arose partly within the Oudh area.

Analysis: Clause 14 was construed on its plain language, which permits the Lucknow Bench to exercise jurisdiction in respect of cases arising in the notified areas in Oudh. Territorial jurisdiction under Article 226 is linked to where the cause of action arises, wholly or in part. The expression used in clause 14 was held to include cases where the impugned order or substantial part of the grievance arose at Lucknow. The attempted distinction between a special theory of sitting at Lucknow and the ordinary doctrine of cause of action was rejected as having no legal basis. The earlier interpretation that the Lucknow Bench would have jurisdiction where cause of action arises wholly or partly within the Oudh areas was reaffirmed.

Conclusion: The Lucknow Bench did have jurisdiction and the contrary view of the High Court was erroneous.

Issue (ii): Whether the Explanation to Section 141 of the Code of Civil Procedure, 1908 altered the interpretation of clause 14 so as to displace the rule laid down earlier on jurisdiction.

Analysis: The earlier decision construing clause 14 had proceeded on the language of the Amalgamation Order itself and had not depended upon the Code of Civil Procedure. The Explanation to Section 141 did not affect that interpretation. The High Court's reliance on the Explanation to deny jurisdiction was therefore held to be unjustified.

Conclusion: The Explanation to Section 141 of the Code of Civil Procedure, 1908 did not change the governing interpretation of clause 14.

Final Conclusion: The jurisdictional ruling of the High Court was set aside, the writ petition stood dismissed, and the appeal succeeded in restoring the legal position that territorial jurisdiction under clause 14 depends on the place where the cause of action arises in whole or in part within the notified Oudh areas.

Ratio Decidendi: For jurisdiction under clause 14 of the High Court (Amalgamation) Order, 1948, the decisive test is whether the cause of action arises wholly or partly in the Oudh areas, and that construction is not displaced by the Explanation to Section 141 of the Code of Civil Procedure, 1908.

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