Territorial writ jurisdiction and forum convenience can still justify declining relief in favour of a more appropriate forum.

Article explains that territorial jurisdiction under Article 226(2) depends on whether a material part of the cause of action arose within the High Court's territory, and that even a small but integral part can suffice on the pleadings. It also notes that territorial jurisdiction does not require the Court to entertain every writ petition: the doctrine of forum convenience may justify refusal where another forum is more appropriate, particularly to avoid conflicting proceedings. On the stated facts, the matter was considered more suitably pursued before the Delhi forum, despite territorial jurisdiction in Chennai.

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Issues: (i) Whether the High Court had territorial jurisdiction under Article 226 to entertain the writ petitions challenging the FIR and consequential notices. (ii) Whether, despite such jurisdiction, the writ petitions should be entertained in view of the doctrine of forum convenience.

Issue (i): Whether the High Court had territorial jurisdiction under Article 226 to entertain the writ petitions challenging the FIR and consequential notices.

Analysis: The Court held that jurisdiction under Article 226(2) depends on whether the cause of action, wholly or in part, arose within the territorial limits of the Court. On the pleadings and the FIR, searches were conducted in Chennai and part of the alleged events were stated to have occurred there. The Court applied the settled principle that even a small but material and integral part of the cause of action is sufficient to confer territorial jurisdiction, and that the question must be decided on the averments in the petition.

Conclusion: The High Court held that it had territorial jurisdiction to entertain the writ petitions.

Issue (ii): Whether, despite such jurisdiction, the writ petitions should be entertained in view of the doctrine of forum convenience.

Analysis: The Court held that territorial jurisdiction does not compel exercise of writ jurisdiction in every case. Even where part of the cause of action arises within the jurisdiction, the Court may decline to entertain the matter if another forum is more convenient and if entertaining the case may lead to conflicting views. Since the FIR was registered in Delhi, the Special Judge at Delhi was seized of the matter, and the Delhi High Court had supervisory jurisdiction over that court, the Delhi forum was found more appropriate.

Conclusion: The Court declined to entertain the writ petitions and directed the parties to approach the Delhi High Court.

Final Conclusion: The writ petitions were not entertained in this Court notwithstanding territorial jurisdiction, because the Court applied the doctrine of forum convenience and directed the parties to seek relief before the Delhi High Court.

Ratio Decidendi: Even where part of the cause of action arises within a High Court's territory, that Court may refuse to exercise writ jurisdiction on the ground of forum convenience if another forum is more appropriate and entertaining the petition may create conflicting judicial outcomes.

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