Territorial writ jurisdiction under Article 226 does not reach private complaint proceedings when the impugned criminal acts occur outside the High Court's limits.

Article 226(2) confines territorial writ jurisdiction to cases where the impugned judicial act arises wholly or in part within the High Court's limits. In a private complaint under Section 138 of the Negotiable Instruments Act, the complainant is not the writ target; the relevant acts are the Magistrate's cognizance under Section 190(1)(a) CrPC and issuance of process under Section 204 CrPC. Because those acts occurred outside the High Court's territory, no writ of certiorari or prohibition could issue to quash or restrain the criminal proceedings, even though part of the underlying cause of action arose within the State.

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Issues: Whether the High Court could exercise jurisdiction under Article 226 to quash a complaint under Section 138 of the Negotiable Instruments Act and prohibit proceedings before a Magistrate's Court outside its territorial jurisdiction on the ground that part of the cause of action arose within the State.

Analysis: The power under Article 226(2) depends on the cause of action arising wholly or in part within the territorial limits of the High Court, but that principle governs judicial review of the action sought to be restrained. In a private complaint, the complainant is not amenable to writ jurisdiction, and the relevant judicial act is the Magistrate's taking cognizance under Section 190(1)(a) of the Code of Criminal Procedure, 1973 and issuing process under Section 204 of that Code. Since those acts occurred in Coimbatore, outside the territorial limits of the High Court, no writ of certiorari or prohibition could issue. The observation in the earlier case supporting Article 226 jurisdiction in such matters was treated as obiter and the contrary view was preferred.

Conclusion: The High Court had no territorial jurisdiction under Article 226 to quash or restrain proceedings in the foreign criminal court on a private complaint under Section 138 of the Negotiable Instruments Act.

Ratio Decidendi: Article 226(2) does not confer jurisdiction to interfere with proceedings in a criminal court outside the High Court's territory where the impugned judicial act occurred wholly outside the State, even if part of the underlying transaction arose within the State and the complaint is based on a private complaint.

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