Territorial jurisdiction in SARFAESI challenges turns on where Section 13(4) enforcement occurs, not merely where notices are served.

Territorial jurisdiction for a Section 17 SARFAESI challenge depends on whether the integral cause of action arises within the Tribunal's local limits. Where the challenge is directed against measures under Section 13(4), jurisdiction ordinarily lies with the Tribunal where the secured assets are situated and enforcement action is taken. Earlier steps such as demand notice, representation, consideration of representation, or communication of decision may form part of the factual background, but they do not by themselves confer jurisdiction. Mere service of notice or communication at another place, or the bank's head office being located there, is insufficient.

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Issues: Whether the Debt Recovery Tribunal at Calcutta had territorial jurisdiction to entertain an application under Section 17 of the SARFAESI Act challenging measures taken under Section 13(4) in relation to secured assets situated in Gujarat.

Analysis: Jurisdiction of the Tribunal under Section 19(1)(c) of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 depends on whether the cause of action, wholly or in part, arises within its local limits. In a SARFAESI challenge under Section 17, the right to approach the Tribunal matures only when the secured creditor takes measures under Section 13(4). The earlier steps under Section 13(2) and Section 13(3A), including service of demand notice, submission of representation, consideration of the representation, and communication of decision, may form part of the factual chain, but they do not constitute the integral part of the cause of action for territorial jurisdiction where the challenge is to enforcement under Section 13(4). The measures under Section 13(4) are in the nature of execution of the creditor's decision, and the competent Tribunal is the one within whose territorial jurisdiction the secured assets are situated and the enforcement action is taken. Mere service of notice at Kolkata, communication to the borrower at Kolkata, or the location of the bank's head office at Kolkata was insufficient to confer jurisdiction.

Conclusion: The Calcutta DRT lacked territorial jurisdiction to entertain the Section 17 application, and the challenge to the appellate order failed.

Final Conclusion: The revisional application was rejected, and the finding that the Calcutta DRT had no territorial jurisdiction to hear the SARFAESI challenge was upheld.

Ratio Decidendi: For a Section 17 SARFAESI challenge, territorial jurisdiction lies where the integral part of the cause of action arises, and in cases concerning measures under Section 13(4), mere service of notices or communications at another place does not by itself confer jurisdiction.

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