Territorial jurisdiction and objective satisfaction govern Chapter XX-C pre-emptive purchase; vague comparables and valuation lapses vitiated the order.

Territorial jurisdiction under Article 226 was attracted because part of the cause of action arose where the impugned notice was issued and the reply was considered. The pre-emptive purchase order under Chapter XX-C was unsustainable because the show-cause notice lacked adequate particulars for meaningful comparison with cited sale instances, the authority acknowledged superior location differences, and it did not apply a consistent approach to tenancy and conversion charges. The record also failed to show the positive, objective satisfaction required to conclude that the property was undervalued by more than 15 per cent. The impugned orders were therefore liable to be quashed.

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Issues: Whether the High Court had territorial jurisdiction under Article 226, and whether the order of pre-emptive purchase under Chapter XX-C was vitiated for want of proper comparables, failure to account for tenancy and conversion charges, and absence of objective satisfaction under section 269UD.

Analysis: The cause of action partly arose within the High Court's territorial jurisdiction because the impugned notice was issued and the reply was considered at Ahmedabad. On merits, the show-cause notice was found to be vague because it did not disclose adequate particulars for comparing the property with the cited sale instances. The authority itself accepted that the cited properties were in a superior location and also failed to apply a consistent approach to the effect of sitting tenants and conversion charges. The record further showed that the authority had not reached a positive, objective satisfaction on material evidence that the property was undervalued by more than 15 per cent., as required for pre-emptive purchase under the Act.

Conclusion: The High Court had jurisdiction, and the impugned orders under Chapter XX-C were unsustainable and liable to be quashed.

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