Territorial limits of writ jurisdiction bar challenge to revisional orders issued outside the High Court's jurisdiction.

Article 226 writ jurisdiction is territorially confined and can be exercised only against a person, authority, or Government within the High Court's territorial limits. Where the revisional authority is located outside those limits, its final order is not amenable to writ challenge there. Earlier local orders are treated as merged in the revisional order, so they cannot be attacked separately once superseded. The distinction between a revision being dismissed and a revision resulting in modification or substitution of the original order was rejected for jurisdictional purposes.

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Issues: Whether the High Court could exercise jurisdiction under Article 226 of the Constitution of India to issue writs against orders ultimately made by the Assistant Custodian General at Delhi, and whether the orders of the local tribunals could be treated as independently challengeable notwithstanding the revisional orders.

Analysis: Article 226 was held to be territorially confined: the writ power extends only within the High Court's territorial jurisdiction and can be exercised only against a person, authority, or Government within those territories. The revisional authority whose orders finally governed the cases was permanently located at Delhi, outside the territorial limits of the Court, and therefore was not amenable to its writ jurisdiction. The earlier orders of the local authorities were treated as having merged in the revisional orders, so the challenge could not be confined to the subordinate orders alone. The distinction suggested between cases where revision is dismissed and cases where the revisional authority modifies or substitutes its own order was rejected for purposes of jurisdiction under Article 226.

Conclusion: The High Court had no jurisdiction to issue the writs, and the appeals failed.

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