Territorial jurisdiction under Article 226(2) requires a material cause of action nexus; summons and replies alone do not confer it.

Territorial jurisdiction under Article 226(2) depends on whether the pleaded facts form a material and integral part of the cause of action with a direct nexus to the relief sought. Mere issuance or receipt of summons or notices at a registered office, or replies sent from that place, does not by itself confer jurisdiction; recording of statements there also is insufficient without more. The "evil consequence" principle applies only where the impugned action infringes a legal right within the forum territory. On the pleaded facts, the dispute concerned reopening of an investigation initiated outside the State, with no shown infringement of rights within the Calcutta High Court's territorial limits, so the writ petition was not maintainable.

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Issues: Whether the writ petition was maintainable in the Calcutta High Court on the basis that summons, replies, and statements relating to the investigation were issued or recorded at Kolkata so as to constitute part of the cause of action within Article 226(2) of the Constitution of India.

Analysis: Territorial jurisdiction under Article 226(2) depends on a bundle of material facts that constitute the cause of action and have a direct nexus with the relief claimed. Mere receipt of summons or notices at the petitioner's registered office, or the sending of replies from that office, does not by itself constitute an integral part of the cause of action. Likewise, recording of statements at the registered office does not, without more, confer jurisdiction. The contention based on evil consequence also failed because that principle applies where the impugned action infringes a legal right within the forum territory. On the pleaded facts, the grievance concerned reopening of an investigation initiated outside the State, and no infringement of rights within the territorial jurisdiction was shown.

Conclusion: The writ petition was not maintainable for want of territorial jurisdiction, and the objection of the respondent authorities succeeded.

Ratio Decidendi: For purposes of Article 226(2), issuance of summons or notices to a place, or receipt of replies therefrom, does not create territorial jurisdiction unless those facts form a material and integral part of the cause of action directly connected with the relief sought.

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