Territorial jurisdiction under Article 226(2) requires cause of action; Section 160 notice alone did not confer writ jurisdiction.

Article 226(2) territorial jurisdiction depends on at least a part of the cause of action arising within the High Court's territory. Service of a notice under Section 160 CrPC in Uttar Pradesh did not by itself create cause of action, because the alleged offence, investigation, and impugned criminal proceedings were wholly connected with Gujarat. The notice was only an intimation of investigative action, and apprehension of arrest or reliance on another case was insufficient to confer jurisdiction. The writ petitions were therefore not maintainable before the High Court for want of territorial jurisdiction, and the parties were left to pursue remedies before the appropriate forum.

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Issues: Whether the High Court had territorial jurisdiction under Article 226(2) of the Constitution of India to entertain the writ petitions merely because notices under Section 160 of the Code of Criminal Procedure were served within Uttar Pradesh when the alleged offence and investigation were wholly connected with Gujarat.

Analysis: The Court held that the power under Article 226(2) is attracted only when at least a part of the cause of action arises within the territorial jurisdiction of the High Court. Service of a notice under Section 160 of the Code of Criminal Procedure within Uttar Pradesh did not itself create a cause of action, because the investigation and the impugned criminal proceedings were based in Gujarat. The notice was only an intimation of investigative action and did not alter the place where the cause of action arose. The apprehension of arrest and reliance on another case were also found insufficient to confer jurisdiction.

Conclusion: The writ petitions were not maintainable before the High Court for want of territorial jurisdiction, and the challenge failed.

Final Conclusion: The Court declined to entertain the writ petitions on merits and left the parties to pursue any remedy before the appropriate forum having jurisdiction.

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