Territorial writ jurisdiction under Article 226(2) extends where a material part of the cause of action arises within the State.

Article 226(2) confers territorial writ jurisdiction on a High Court where a material part of the cause of action arises within its limits, even if the respondent authority is based elsewhere, and the inquiry is to be read consistently with Section 20 CPC principles. Here, the employer's factory in Gujarat, the labour proceedings in Gujarat, and the wage claim together constituted a material part of the cause of action within Gujarat. The Gujarat High Court therefore had territorial jurisdiction to entertain the writ petition, the objection to maintainability failed, and the dispute had to be decided on merits.

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Issues: Whether the Gujarat High Court had territorial jurisdiction under Article 226(2) of the Constitution of India read with Section 20 of the Code of Civil Procedure, 1908 to entertain the writ petition.

Analysis: Article 226(2) permits a High Court to exercise writ jurisdiction where the cause of action, wholly or in part, arises within its territorial limits, notwithstanding that the seat of the respondent authority or person lies elsewhere. Applying that principle, the relevant events included the employer's factory at Porbandar in Gujarat, the labour proceedings before the Labour Court at Junagadh in Gujarat, and the claim relating to unpaid wages of workmen. These facts constituted a material part of the cause of action within Gujarat, and the jurisdictional inquiry was to be guided consistently with the principles reflected in Section 20 of the Code of Civil Procedure, 1908.

Conclusion: The Gujarat High Court had territorial jurisdiction to entertain the writ petition. The objection to maintainability failed, and the matter required adjudication on merits.

Ratio Decidendi: Where a material part of the cause of action arises within a High Court's territorial jurisdiction, it may entertain a writ petition under Article 226(2) of the Constitution of India even if the respondent's seat or residence is outside that territory.

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