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Issues: Whether the High Court had territorial jurisdiction under Article 226 to entertain the writ petition challenging the detention order and grounds of detention when the order was passed and served in Maharashtra and the detenu's alleged prejudicial activities arose there, though the detenu was arrested in Punjab.
Analysis: Territorial jurisdiction under Article 226 depends on whether a part of the cause of action arises within the Court's limits. Mere arrest of the detenu in Punjab, without any material showing that the detention order, its service, the grounds of detention, or the prejudicial activities had any relevant connection with Punjab, was insufficient to confer jurisdiction. The operative facts were centered in Maharashtra: the detention order was made there, the grounds were served there, and the representation was dealt with there. On those facts, no part of the cause of action arose within Punjab and Haryana.
Conclusion: The High Court had no territorial jurisdiction to entertain the petition, and the challenge to the detention order was not maintainable before it.
Ratio Decidendi: For jurisdiction under Article 226, the mere arrest of a detenu within a State does not confer territorial jurisdiction unless a part of the cause of action arises within that State.