Territorial jurisdiction under Article 226(1A) exists when part of the cause of action arises within the State, despite outside service.

Territorial jurisdiction under Article 226(1A) existed where material facts forming part of the cause of action arose within the State, even though the detention orders were signed and served outside Gujarat. The detenus' residence and business were in Gujarat, their earlier detention had commenced at Baroda, and the impugned orders continued restraint on their liberty, movement, residence, and business within the State. Article 19 was relevant only incidentally to identify the rights affected and could be considered for the limited jurisdictional inquiry. The writ petitions were therefore maintainable in the High Court.

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Issues: Whether the High Court had territorial jurisdiction under Article 226(1A) of the Constitution of India to entertain the writ petitions on the footing that a part of the cause of action arose within Gujarat.

Analysis: The jurisdictional inquiry depended on whether, notwithstanding that the detention orders were served at Jaipur and signed outside the State, material facts connecting the challenge to Gujarat established that a part of the cause of action arose within the Court's territorial limits. The detenus' residence and business were in Gujarat, their earlier detention had commenced at Baroda, and the effect of the fresh detention orders was to continue the restraint upon their liberty, movement, residence, and business within the State. Article 19 was relevant only incidentally for identifying the nature of the rights affected, and its operation during emergency did not prevent its being referred to for the limited purpose of determining jurisdiction under Article 226(1A).

Conclusion: The High Court had jurisdiction because a part of the cause of action arose within Gujarat, and the writ petitions were maintainable.

Ratio Decidendi: For the purpose of Article 226(1A), territorial jurisdiction exists where material facts constituting part of the cause of action arise within the State, even if the impugned detention order is served or signed outside the State.

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