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Issues: (i) Whether the Chief Justice of the High Court had authority to insert an explanation deeming a writ case to arise in a particular district by reference to cause of action for the purpose of allocating matters between Jodhpur and the Jaipur Bench; (ii) whether the use of the expression "exclusive jurisdiction" in relation to the Jaipur Bench was unwarranted.
Issue (i): Whether the Chief Justice of the High Court had authority to insert an explanation deeming a writ case to arise in a particular district by reference to cause of action for the purpose of allocating matters between Jodhpur and the Jaipur Bench.
Analysis: The Presidential Order under the States Reorganisation Act established a permanent Bench at Jaipur by reference to specified territorial districts and permitted the Chief Justice only to direct that a case or class of cases arising in those districts be heard at Jodhpur. That power did not extend to defining where the cause of action in a writ case would be deemed to arise. The power under the Rajasthan High Court Ordinance concerning distribution of business and roster-making was merely administrative and could not be used to enact a deeming rule on territorial jurisdiction. The question where a cause of action arises is to be decided judicially in each case, not by a general administrative order. The impugned explanation therefore cut across the scheme of the Presidential Order and encroached upon judicial determination of jurisdiction.
Conclusion: The explanation inserted by the Chief Justice was beyond jurisdiction and invalid.
Issue (ii): Whether the use of the expression "exclusive jurisdiction" in relation to the Jaipur Bench was unwarranted.
Analysis: The Presidential Order created a territorial bifurcation between the principal seat and the permanent Bench, and matters were to be heard according to the district from which the case arose, subject to the Chief Justice's limited discretionary power under the proviso. In this setting, describing the Jaipur Bench as having exclusive jurisdiction over cases arising in the specified districts merely reflected the territorial scheme. The governing test remained whether the cause of action arose wholly or partly within the relevant territorial area, as understood under Article 226 principles.
Conclusion: The expression "exclusive jurisdiction" was not erroneous.
Final Conclusion: The appeal failed because the impugned explanation could not be sustained, while the territorial allocation of jurisdiction between the two seats remained valid on the basis of where the cause of action arose.
Ratio Decidendi: A Chief Justice's administrative power to distribute business and frame a roster does not include authority to create a deeming rule for where a writ cause of action arises; territorial jurisdiction between a principal seat and a permanent Bench must be determined judicially in each case according to the actual cause of action.