Territorial writ jurisdiction under Article 226 failed where no material cause of action arose in Uttar Pradesh.

Article 226 jurisdiction depended on whether any part of the cause of action arose within Uttar Pradesh. The impugned orders were made in Bihar by the Cane Commissioner and concerned villages in Bihar, so the territorial connection was absent. Mere communication of one order to the petitioner's factory in Uttar Pradesh did not create a material part of the cause of action because the legally operative communication was by Gazette notification. A reservation under Clause 6(a) of the Sugarcane (Control) Order, 1966 conferred only a privilege, not an enforceable right against growers; enforceable obligations would arise only under later orders under Clause 6(c) or 6(d), which were not issued. The writ petition was therefore not maintainable in the Allahabad High Court.

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Issues: Whether the writ petition was maintainable in the High Court at Allahabad when no part of the cause of action arose within Uttar Pradesh.

Analysis: Jurisdiction under Article 226 depended on whether the petitioner could show that the cause of action, wholly or in part, arose within the territorial limits of the Court. The impugned orders were passed in Bihar by the Cane Commissioner and related to villages situate in Bihar. Communication of one order to the petitioner's factory in Uttar Pradesh did not create a material part of the cause of action, because the legally operative communication was by notification in the official Gazette. The modified reservation order also did not frustrate the petitioner's contracts, since a reservation under Clause 6(a) of the Sugarcane (Control) Order, 1966 conferred only a privilege and no enforceable right against growers; enforceable obligations arose only under later orders under Clause 6(c) or 6(d), which had not been passed. The alleged decision of a Joint Sugarcane Board had no statutory force and could not found jurisdiction.

Conclusion: No part of the cause of action arose within Uttar Pradesh, and the writ petition was not cognizable by the Court.

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