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Issues: Whether the High Court at Bombay was justified in declining to entertain the writ petition for quashing the criminal proceedings on the ground that the cause of action, investigation, and records were centred in Ranchi and that the court lacked territorial jurisdiction.
Analysis: Territorial jurisdiction in criminal matters is primarily determined by the place where the alleged offence was committed and by the averments in the complaint or charge sheet. Section 177 of the Code of Criminal Procedure, 1973 requires offences to be inquired into and tried by the court within whose local jurisdiction they were committed, while the existence of some connecting facts elsewhere does not by itself confer jurisdiction to interfere with proceedings already pending before the competent court. On the facts disclosed, the investigation had been completed at Ranchi, the charge sheet and records were before the Special Judge there, and the complaint alleged a conspiracy and fraudulent conduct substantially centred in Ranchi.
Conclusion: The High Court was justified in refusing to entertain the writ petition, and the challenge to that order failed.
Ratio Decidendi: In criminal matters, jurisdiction to interfere under writ powers depends on where the offence and material facts giving rise to the prosecution are situated; where the complaint and investigation show that the cause of action and records are substantially before the court having jurisdiction at another place, the High Court should not entertain a quashing petition merely because some related facts are said to have occurred elsewhere.