Territorial jurisdiction in FIR quashing petitions turns on where the case was registered, not civil cause of action.

Territorial jurisdiction for quashing an FIR under Section 482 of the Code of Criminal Procedure depends on the situs of the authority that registered the case, not on the civil law concept of cause of action. The distinction between writ jurisdiction under Article 226 and inherent criminal jurisdiction was emphasised: cause of action may matter for writ petitions, but it does not govern criminal procedure. Place of inquiry and trial is determined by where the offence was committed, subject to Sections 177 and 178 of the Code. The petition was therefore not maintainable before the Madras High Court because the FIR had been registered outside its territorial jurisdiction.

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Issues: Whether the High Court's inherent power under Section 482 of the Code of Criminal Procedure, 1973 can be exercised to quash an FIR registered within the territorial jurisdiction of another High Court, and whether the civil law concept of cause of action can be imported into criminal law for determining such jurisdiction.

Analysis: The petition questioned territorial maintainability because the FIR was registered in Mumbai, while the petitioner sought relief in the Madras High Court. The reasoning distinguished writ jurisdiction under Article 226 of the Constitution of India from inherent criminal jurisdiction under Section 482 of the Code of Criminal Procedure, 1973. It held that the "cause of action" principle under Article 226(2) governs writ petitions, but that concept is not part of criminal procedure. The place of inquiry and trial in criminal law is controlled by the place where the offence was committed, subject to the statutory exceptions in Sections 177 and 178 of the Code of Criminal Procedure, 1973. The larger-bench ruling in Dashrath Rupsingh Rathod was relied on to hold that civil law notions of cause of action cannot be used to determine criminal territorial jurisdiction. Accordingly, for a petition under Section 482, the relevant consideration is the situs of the authority that registered the case, not whether a part of the alleged offence arose within the forum State.

Conclusion: The petition was not maintainable before the Madras High Court because the FIR had been registered outside its territorial jurisdiction.

Ratio Decidendi: For quashing an FIR under Section 482 of the Code of Criminal Procedure, 1973, territorial jurisdiction depends on the situs of the authority that registered the case, and the civil law concept of cause of action cannot be imported into criminal law.

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