Territorial jurisdiction under Article 226 failed where the material facts and PMLA proceedings were centered in Mumbai.

Territorial jurisdiction under Article 226 depends on whether a material and substantial part of the cause of action arises within the court's limits. Because the ECIR was registered in Mumbai, the investigation was conducted there, the PMLA complaint was filed there, and the trial was pending there, Delhi had no territorial nexus sufficient to entertain the writ petition. The summons issued in Delhi and the arrest there were treated as incidental facts, not part of the material bundle of facts. The Court also applied forum conveniens and found Mumbai the appropriate forum since the Special Court, prosecution, and evidence were all situated there. The writ petition was properly declined.

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Issues: Whether the Delhi High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain the writ petition challenging the PMLA proceedings and whether the doctrine of forum conveniens warranted refusal to entertain the petition.

Analysis: Territorial jurisdiction under Article 226 depends on whether a material and substantial part of the cause of action arises within the court's limits. The place where the ECIR was registered, the investigation was carried out, the complaint under the PMLA was filed, and the trial was pending was Mumbai. The summons and arrest in Delhi were held insufficient to create jurisdiction, as they were incidental facts and did not constitute the material bundle of facts necessary to sustain the petition. The Court also applied the doctrine of forum conveniens and noted that the Special Court seized of the matter, the prosecution, and the evidence were all in Mumbai, making that forum the more appropriate one.

Conclusion: The Delhi High Court lacked territorial jurisdiction and properly declined to entertain the writ petition.

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