Territorial limits on writ jurisdiction barred challenge to an appellate tribunal outside the court's reach.

Article 226 writ jurisdiction depends on the territorial location of the authority against whom relief is sought, and a High Court cannot issue a writ to an appellate tribunal permanently seated outside its territorial limits. Where an appellate tribunal's award substitutes and becomes enforceable in place of the industrial court's order, quashing only the industrial court's order would amount to indirect interference with the appellate order and could create conflicting obligations. On that basis, the High Court held that it had no jurisdiction to entertain the writ petition or to quash the impugned orders.

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Issues: (i) Whether the High Court could exercise jurisdiction under Article 226 of the Constitution of India to issue a writ against the Labour Appellate Tribunal at Bombay, whose principal seat was permanently located outside the territorial limits of the Court, and whether the order of the industrial court could be quashed indirectly despite the appellate order.

Analysis: The jurisdiction under Article 226 depends on the presence or location within the territorial limits of the person or authority to whom the writ is issued. The Appellate Tribunal was constituted under the Industrial Disputes (Appellate Tribunal) Act, 1950, with its principal seat at Bombay under Sections 6 and 8, and the decision of the Appellate Tribunal became enforceable and substituted the industrial court's order under Sections 15 and 16. In light of the Supreme Court's ruling on territorial limits of writ jurisdiction, the High Court could not direct a writ to an authority permanently located outside its jurisdiction. Quashing only the industrial court's order would amount to indirect interference with the appellate order and create conflicting obligations, including possible contempt consequences under Section 30(3).

Conclusion: The High Court had no jurisdiction to entertain the writ petition or to quash the orders impugned before it.

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