Court dismisses petition lacking territorial jurisdiction, emphasizing authority's situs over crime location.

The court dismissed the petition as it lacked territorial jurisdiction to quash an FIR registered in another High Court's jurisdiction. It held that the inherent power under Section 482 of Cr.P.C. and the writ jurisdiction under Article 226 do not extend beyond the High Court's territorial limits based on the cause of action. The court emphasized that jurisdiction is determined by the situs of the authority who registered the case, not by the place of the crime's commission.

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Issues Involved:
1. Whether the inherent power of the High Court under Section 482 of the Code of Criminal Procedure extends beyond its territorial limits to quash an FIR registered in another High Court's jurisdiction.
2. Whether the civil law concept of "cause of action" can be imported into criminal law.
3. Whether the writ jurisdiction of the High Court can be invoked to quash an FIR registered outside its territorial jurisdiction.

Issue-wise Detailed Analysis:

1. Jurisdiction under Section 482 of Cr.P.C.
The primary issue was whether the inherent power of the High Court under Section 482 of the Code of Criminal Procedure extends beyond its territorial limits to quash an FIR registered in another High Court's jurisdiction. The petitioner argued that part of the cause of action arose in Chennai, thus conferring jurisdiction to the Madras High Court. The court examined the jurisprudence and concluded that for the purpose of Section 482, the jurisdiction is determined by the situs of the authority who registered the case, not by the place of commission of the crime. The court referenced the Supreme Court's decision in Navinchandra N. Majithia, which dealt with Article 226 but clarified that it did not extend to Section 482 of Cr.P.C. Therefore, the court held that it lacked territorial jurisdiction to entertain the petition.

2. Importing Civil Law Concept of "Cause of Action" into Criminal Law
The court addressed whether the civil law concept of "cause of action" could be imported into criminal law. It noted that the term "cause of action" is foreign to the Code of Criminal Procedure. The court cited the Supreme Court's decision in Dashrath Rupsingh Rathod, which emphasized that the concept of "cause of action" pertinent to civil law is not applicable to criminal law. The court concluded that the jurisdiction for criminal matters is based on the place of commission of the crime and the situs of the authority, not on the cause of action.

3. Writ Jurisdiction under Article 226
The court also considered whether its writ jurisdiction under Article 226 of the Constitution could be invoked to quash an FIR registered outside its territorial jurisdiction. The court discussed the historical context and amendments to Article 226, specifically Clause 2, which allows High Courts to exercise jurisdiction where the cause of action arises. However, it clarified that this extension applies to writ jurisdiction and not to Section 482 of Cr.P.C. The court reaffirmed that its writ jurisdiction does not extend to quashing criminal cases pending in authorities outside its territorial limits.

Conclusion:
The court dismissed the petition for want of territorial jurisdiction, emphasizing that the inherent power under Section 482 of Cr.P.C. and the writ jurisdiction under Article 226 do not extend beyond the territorial limits of the High Court based on the cause of action. The court concluded that the only criterion for jurisdiction under Section 482 is the situs of the authority who registered the case. Consequently, the petition and the connected miscellaneous petition were dismissed.

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