Territorial jurisdiction under Article 226 depends on cause of action; forum conveniens applies only in exceptional cases.

Territorial jurisdiction under Article 226 is attracted where even part of the cause of action arises within the High Court's territory, and the situs of the appellate authority is a relevant but not decisive factor. The doctrine of forum conveniens may justify refusal of jurisdiction only after a factual assessment of comparative convenience, not merely because the appellate body is located elsewhere. Where the appellate order itself gives rise to the cause of action, the petitioner ordinarily has a choice of forum, and jurisdiction should be declined only in exceptional cases where another forum is clearly more suitable. The writ petition was therefore maintainable in Delhi, and the summary refusal of jurisdiction was unsustainable.

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Issues: Whether the writ petition was maintainable in the Delhi High Court on the basis that the appellate tribunal was situated in Delhi, and whether the doctrine of forum conveniens justified refusal to exercise jurisdiction.

Analysis: The principle of territorial jurisdiction under Article 226 permits a writ petition where even a part of the cause of action arises within the High Court's territory. The location of the appellate authority is therefore a relevant cause of action factor, but it is not by itself ative. The doctrine of forum conveniens may still be applied in an appropriate case, but only after examining the factual matrix and the comparative convenience of the available forums. Earlier precedent holding that the situs of the appellate authority alone makes that forum conveniens was not accepted in absolute terms. The judgment clarified that where the appellate order itself furnishes cause of action, the petitioner ordinarily has a choice of forum, and the court should decline jurisdiction only in extreme cases where another forum is clearly more suitable.

Conclusion: The writ petition was maintainable in Delhi and the single-paragraph order declining jurisdiction was unsustainable for want of proper application of forum conveniens.

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