Territorial writ jurisdiction under Article 226(2): a High Court cannot refuse a petition merely because another forum may seem more effective.

Article 226(2) permits a High Court to entertain a writ petition where any part of the cause of action arises within its territorial limits, even if the authority is located elsewhere. Territorial jurisdiction depends on the pleaded facts disclosing a part of the cause of action in the forum State, and a High Court cannot decline to proceed merely because another High Court may be a more effective forum. On the facts described, the Delhi High Court did not find that no part of the cause of action arose in Delhi, and its refusal on the basis of forum effectiveness was erroneous; the matter required reconsideration on merits.

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Issues: Whether the Delhi High Court was justified in declining to proceed with the writ petition on the ground that the Allahabad High Court could deal with the grievance more effectively despite the existence of territorial jurisdiction under Article 226(2) of the Constitution of India.

Analysis: Article 226(2) permits a High Court to exercise writ jurisdiction where the cause of action wholly or in part arises within its territorial limits, notwithstanding that the seat of Government or authority is elsewhere. The determining question is whether the facts pleaded disclose a part of the cause of action within the forum State. A High Court cannot refuse to entertain a writ petition merely on the view that another High Court may deal with the grievance more effectively if territorial jurisdiction otherwise exists. The impugned order did not hold that no part of the cause of action arose within Delhi; instead, it proceeded on the basis that the Allahabad High Court would be a more effective forum.

Conclusion: The Delhi High Court erred in declining to proceed on that basis, and the matter had to be reconsidered on merits.

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