Territorial jurisdiction under Article 226(2) extends where part of the cause of action arises within the Bench's limits.

The Gwalior Bench's territorial jurisdiction under the Presidential Order made under Section 51(2) of the States Reorganisation Act, 1956 was construed consistently with Article 226(2) of the Constitution, so that a petition could be entertained where the whole or part of the cause of action arose within the specified revenue districts. On that test, the impugned order was held to have operated at Gwalior, where the petitioner was posted, and therefore a part of the cause of action arose within the Bench's limits. The earlier view in Kanti Prasad was held to have overlooked this aspect and was overruled.

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Issues: Whether the Gwalior Bench had territorial jurisdiction to entertain the writ petition on the basis that a part of the cause of action arose within the specified revenue districts, and whether the earlier view in Kanti Prasad on this point required reconsideration.

Analysis: The Presidential Order under Section 51(2) of the States Reorganisation Act, 1956 confined the Gwalior Bench's jurisdiction to cases arising in the specified revenue districts, which had to be understood consistently with Article 226(2) of the Constitution of India. The expression "cases arising" was held to mean cases where the whole or a part of the cause of action arose within those districts. Applying that test, the consequences of the impugned order were treated as having fallen on the petitioner at Gwalior, where he was posted, so a part of the cause of action arose within the Bench's territorial limits. The earlier decision in Kanti Prasad was found not to have considered this aspect fully and was held to be incorrect.

Conclusion: The Gwalior Bench had jurisdiction to entertain the petition, and Kanti Prasad was overruled.

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