Territorial jurisdiction for FIR quashing turns on where the complaint is registered, not where parties reside or incidents occurred.

Territorial jurisdiction under Article 226 to quash an FIR depends on where the relevant cause of action arises, namely where the complaint is lodged and the criminal proceeding is registered. Sections 177 and 178 CrPC govern place of inquiry and trial, but do not determine High Court jurisdiction under Article 226. Applying that principle, a petition challenging an FIR registered at Jaipur could not be entertained by the Gujarat High Court, as the relevant proceeding was pending outside its territorial limits. The petition was therefore not maintainable before that Court and was dismissed without examination of the merits.

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Issues: Whether the High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain a petition for quashing an FIR registered at Jaipur.

Analysis: Territorial jurisdiction under Article 226 depends on whether the cause of action, wholly or in part, arises within the territorial limits of the Court. For a petition seeking quashing of an FIR, the relevant cause of action is the place where the complaint is lodged and the criminal proceeding is registered, not merely the residence of the parties or the places where some alleged incidents may have occurred. The provisions of Sections 177 and 178 of the Code of Criminal Procedure, 1973 govern place of inquiry and trial for offences and do not determine the territorial jurisdiction of a High Court under Article 226. On the facts, the complaint was registered at Jaipur and the petition was directed against that Rajasthan FIR.

Conclusion: The High Court lacked territorial jurisdiction to entertain the petition.

Final Conclusion: The petition was not maintainable before this High Court and was dismissed without examination of the merits.

Ratio Decidendi: A writ petition seeking quashing of an FIR must be filed before the High Court within whose territorial jurisdiction the complaint or criminal proceeding is pending, because territorial jurisdiction under Article 226 turns on the situs of the relevant cause of action.

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