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Issues: Whether the Madras High Court had territorial jurisdiction under Article 226(2) of the Constitution of India to entertain the writ petitions when the patent applications, revocation proceedings, and the situs of the appellate authority were substantially connected with Mumbai, and whether the doctrine of forum conveniens warranted relegating the parties to the Bombay High Court.
Analysis: The place where an appellate order is passed may form part of the cause of action, but territorial jurisdiction under Article 226(2) is not compelled merely because some hearing or pronouncement occurred within the territorial limits of a High Court. The material facts showed that the petitioners' business, the patent filings, the registration, and the revocation-related proceedings were centred at Mumbai, while the hearing at Chennai was only an arrangement for convenience because the Circuit Bench at Mumbai had infrequent sittings. In such circumstances, the situs of the principal controversy remained Mumbai, and the availability of jurisdiction at Chennai was outweighed by the doctrine of forum conveniens.
Conclusion: The writ petitions were not maintainable in the Madras High Court, and the parties were required to pursue the proceedings before the competent court at Mumbai.
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