Territorial jurisdiction under Article 226(2) requires a material cause of action; mere receipt of a rejection letter is insufficient.

Territorial jurisdiction under Article 226(2) depends on whether an integral and material part of the cause of action arose within the Court's limits. Mere receipt at a petitioner's Calcutta office of a communication rejecting a non-statutory representation did not, by itself, create jurisdiction where the impugned approvals operated outside the Court's territory and the pleadings showed no legally relevant effect within Calcutta. The objection to territorial jurisdiction was not waived because the respondents raised it at the threshold and their limited procedural participation did not amount to submission on the merits or acquiescence.

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Issues: Whether the High Court had territorial jurisdiction under Article 226(2) on the basis that the rejection communication was received at the petitioners' Calcutta office and whether the respondents were precluded from raising the objection of territorial jurisdiction.

Analysis: An objection to territorial jurisdiction can be waived, but only where the party, by its conduct, submits to the jurisdiction or takes steps on the merits after failing to object at the earliest opportunity. Here the respondents raised the objection at the threshold of hearing, and their limited procedural participation did not amount to waiver or acquiescence. On territorial jurisdiction, the governing test is whether a material and integral part of the cause of action arose within the Court's limits. Mere receipt in Calcutta of a communication rejecting a non-statutory representation did not form an integral part of the lis, especially when the impugned approvals were granted and operated entirely outside the Court's territorial limits and the pleadings did not show that the rejection communication itself caused a legally relevant effect within Calcutta.

Conclusion: The objection to territorial jurisdiction was not waived, and no part of the cause of action arose within the territorial jurisdiction of the High Court.

Ratio Decidendi: For Article 226(2), territorial jurisdiction is attracted only when an integral and material part of the cause of action arises within the Court's limits, and mere receipt of a non-statutory communication at the petitioner's office does not by itself confer jurisdiction.

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