Territorial jurisdiction under Article 226 requires a material cause of action nexus; residence or receipt of communication alone is insufficient.

Territorial jurisdiction under Article 226 depends on whether a material part of the cause of action arose within the Court's limits, and mere residence of the petitioner, sending a representation from Madras, or receipt of the rejection order there was insufficient to establish that nexus. The detenu was apprehended, detained, and served with the rejection order at Calcutta, and the record did not show ordinary residence in Tamil Nadu or other sufficient local connection. The Madras High Court therefore held that the writ petition was not maintainable for want of territorial jurisdiction and upheld the jurisdictional objection.

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Issues: (i) Whether the writ petition was maintainable before the High Court on the ground that part of the cause of action arose within its territorial jurisdiction under Article 226 of the Constitution of India.

Issue (i): Whether the writ petition was maintainable before the High Court on the ground that part of the cause of action arose within its territorial jurisdiction under Article 226 of the Constitution of India.

Analysis: Jurisdiction under Article 226 depends on the existence of a cause of action, wholly or in part, within the territorial limits of the Court. Mere residence of the petitioner, the fact that a representation was sent from Madras, or that a rejection copy was received there, does not by itself create a territorial nexus. On the facts, the detenu was apprehended, detained, and served with the rejection order at Calcutta, and the materials did not establish that he ordinarily resided in Tamil Nadu or had sufficient local connections there to found jurisdiction. The authorities relied upon did not assist the petitioner on these facts.

Conclusion: The writ petition was not maintainable before this High Court for want of territorial jurisdiction and the objection to jurisdiction was upheld.

Final Conclusion: The challenge was rejected at the threshold, leaving the petitioner to pursue relief before the Court having jurisdiction over the detention and related actions.

Ratio Decidendi: Territorial jurisdiction under Article 226 arises only when a material part of the cause of action occurs within the Court's limits, and residence of a party or receipt of a communication there, without more, is insufficient.

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