Territorial limits on writ and supervisory jurisdiction bar quashing criminal proceedings before out-of-state Magistrate courts.

Article 226(2) does not extend writ jurisdiction to judicial criminal courts outside the High Court's territorial limits merely because part of the cause of action arose within the State; that principle applies only to authorities or persons amenable to writ control. Judicial orders of courts are not open to certiorari under Article 226, and supervisory control under Article 227 operates only within territorial jurisdiction. On that basis, complaints and criminal proceedings pending before Magistrate courts in New Delhi could not be quashed in the Kerala High Court, while the separate plea based on Section 188 CrPC and place of offence was left open.

---

---

Issues: Whether writ jurisdiction under Article 226 or supervisory jurisdiction under Article 227 could be invoked to quash criminal complaints and proceedings before Magistrate courts situated outside the territorial jurisdiction of the High Court, on the ground that part of the cause of action arose within the State.

Analysis: The Court held that Article 226(2) does not extend writ jurisdiction to judicial criminal courts outside territorial limits, because the cause of action principle applies only against authorities or persons amenable to writ control and not against private complainants or judicial courts. Relying on the settled position that judicial orders of courts are not amenable to certiorari under Article 226, and that control over subordinate courts is exercised under Article 227 only within the High Court's territorial jurisdiction, the Court found that neither provision could be used to challenge proceedings pending before Magistrate courts in New Delhi. The alternative plea based on Section 188 of the Code of Criminal Procedure, 1973 and the place of commission of the offence was left open and no final opinion was expressed on that question.

Conclusion: The petitions were not maintainable before the Court and could not be entertained for quashing the complaints or criminal proceedings.

Ratio Decidendi: Judicial criminal courts outside the High Court's territorial jurisdiction are not amenable to writ or supervisory jurisdiction under Articles 226 and 227 merely because part of the cause of action is said to have arisen within the State.

---