Territorial jurisdiction under the amalgamation order turns on where the proceeding originates, not where the last order was passed.

Article 14 of the U.P. High Courts (Amalgamation) Order, 1948 was construed as assigning cases arising in the specified Oudh areas ordinarily to the Lucknow seat, unless the Chief Justice directs otherwise under the second proviso. Presentation at Allahabad was treated as a procedural irregularity, not as invocation of a forum with concurrent territorial jurisdiction, so such matters were to be returned for filing at Lucknow. The phrase "cases arising in such areas in Oudh" was held to refer to the place where the proceeding originates, including civil, criminal, writ and constitutional proceedings, rather than the situs of the last impugned appellate or revisional order.

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Issues: (i) Whether cases arising in the Oudh areas specified by the Chief Justice under Article 14 of the U.P. High Courts (Amalgamation) Order, 1948 could be presented and decided at Allahabad, or whether they were required to be presented and heard at Lucknow unless transferred under the second proviso. (ii) Whether the expression "cases arising in such areas in Oudh" in the first proviso to Article 14 refers to the place where the proceeding originated, including civil, criminal, writ and certificate proceedings, or to the place of the last impugned order.

Issue (i): Whether cases arising in the Oudh areas specified by the Chief Justice under Article 14 of the U.P. High Courts (Amalgamation) Order, 1948 could be presented and decided at Allahabad, or whether they were required to be presented and heard at Lucknow unless transferred under the second proviso.

Analysis: The majority construed Article 14 as allocating to the judges sitting at Lucknow the work of hearing cases arising in the specified Oudh areas, subject only to an order of the Chief Justice under the second proviso directing a case or class of cases to be heard at Allahabad. It held that the presentation of such a case at Allahabad was not a presentation before a court without jurisdiction, but only a procedural irregularity, so the proper course was return of the papers for filing at Lucknow. The majority rejected the theory of concurrent territorial jurisdiction and treated Lucknow as the forum ordinarily competent for such cases. The separate opinion took the contrary view that the judges at Allahabad retained concurrent territorial jurisdiction, but that view did not prevail.

Conclusion: Cases falling within the jurisdiction of the judges at Lucknow were to be presented at Lucknow and not at Allahabad, and they could not be finally decided at Allahabad unless the Chief Justice had made an order under the second proviso.

Issue (ii): Whether the expression "cases arising in such areas in Oudh" in the first proviso to Article 14 refers to the place where the proceeding originated, including civil, criminal, writ and certificate proceedings, or to the place of the last impugned order.

Analysis: The majority held that the expression refers to the place where the legal proceeding originates, that is, where the cause of action arises in civil matters, where the offence is committed in criminal matters, and, in writ and allied proceedings, where the right originally arose or the impugned legal effect is first felt. It held that petitions under Articles 226, 227, 228, 132, 133 and 134 of the Constitution are also "cases" within Article 14, because they are legal proceedings connected with the original cause. The majority rejected the contention that the situs of the appellate or revisional order alone determines where the case arises.

Conclusion: The expression refers to the place of origin of the proceeding and not to the place of sitting of the last court or authority whose decree or order is challenged.

Final Conclusion: The petition relating to the dispute from Shahjahanpur could not be entertained or heard at Lucknow, and the questions referred were answered in a manner that upheld the ordinary exclusivity of the Lucknow seat for cases arising in the specified Oudh areas, subject to the Chief Justice's power to direct otherwise.

Ratio Decidendi: Where a constitutional or legal proceeding originates in the Oudh areas specified under Article 14, it must ordinarily be instituted and heard at Lucknow, and the expression "cases arising in such areas in Oudh" denotes the place of origin of the proceeding rather than the situs of the challenged appellate or revisional order.

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