Territorial jurisdiction under Article 226 requires an integral cause of action; a second writ on the same facts is barred.

Territorial jurisdiction under Article 226 arises only when facts forming an integral part of the cause of action occur within the Court's limits; incidental facts such as the petitioner's residence or a search at Ghaziabad do not suffice, while the core customs events at Mumbai remained determinative. On that basis, the High Court lacked territorial jurisdiction. A second writ petition on the same facts is barred where an earlier petition was already pursued before a competent forum and the later petition seeks the same relief on the same factual foundation; Rule 7 of the Allahabad High Court Rules, 1952 and res judicata principles were applied. The writ petition was therefore not maintainable.

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Issues: (i) whether the High Court had territorial jurisdiction under Article 226 on the basis of the facts pleaded, and (ii) whether a second writ petition on the same facts was barred.

Issue (i): whether the High Court had territorial jurisdiction under Article 226 on the basis of the facts pleaded.

Analysis: Territorial jurisdiction under Article 226 depends on whether the cause of action, wholly or in part, arises within the Court's limits. For this purpose, the pleaded facts must form an integral part of the cause of action and not merely be incidental or remote. The detention-related notices and the core events giving rise to the controversy arose at Mumbai, where the imported cranes were dealt with and the alleged customs evasion was investigated. The petitioner's residence at Ghaziabad and the search of premises there were held not to be integral parts of the cause of action.

Conclusion: The High Court lacked territorial jurisdiction; the issue was decided against the petitioner.

Issue (ii): whether a second writ petition on the same facts was barred.

Analysis: A second writ petition on the same facts is barred where the earlier petition has already been pursued before a competent forum and the subsequent petition seeks the same relief on the same factual foundation. Rule 7 of the Allahabad High Court Rules, 1952 was treated as prohibiting such a attempt, and the principle of res judicata was applied to writ proceedings when the earlier dismissal operated between the parties.

Conclusion: The second writ petition was barred and this issue was decided against the petitioner.

Final Conclusion: The writ petition failed at the threshold because the territorial cause of action lay outside the Court's jurisdiction and the attempt to re-agitate the matter was not maintainable.

Ratio Decidendi: For Article 226, only facts forming an integral part of the cause of action confer territorial jurisdiction, and a second writ on the same facts is barred when the earlier proceeding has already been pursued before a competent forum.

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