Territorial jurisdiction in criminal complaint proceedings must follow the place of material transactions and cause of action.

A criminal complaint under Section 406 IPC was held unsustainable where the agreements, invoices, supply obligations, and surrounding dealings showed that the material transactions and cause of action arose at Bhadohi rather than New Delhi. The court found that the later agreement and connected facts tied the dispute to Bhadohi, while the parallel civil proceedings also supported that territorial nexus. Filing the complaint in New Delhi was therefore without territorial basis, amounted to an abuse of process, and the complaint and summoning order were quashed for want of jurisdiction.

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Issues: Whether the criminal complaint and summoning order under Section 406 of the Indian Penal Code could be sustained at New Delhi despite the agreements, transactions, and surrounding facts showing Bhadohi as the place of dealing and cause of action.

Analysis: The agreements between the parties, especially the later agreement, indicated that they were entered into at Bhadohi. The supply obligations, invoices, and related dealings were also connected with the Bhadohi office. The surrounding circumstances, including the civil proceedings instituted at Varanasi jurisdiction, supported the conclusion that the material facts arose within the territorial limits of Bhadohi and not Delhi. In these circumstances, filing the criminal complaint at New Delhi was held to be without territorial basis and an abuse of the process of court.

Conclusion: The complaint and the summoning order were without jurisdiction and were quashed in favour of the petitioner.

Ratio Decidendi: A criminal complaint must be instituted before the court having territorial jurisdiction over the material transactions and cause of action, and proceedings filed at a place lacking such jurisdiction amount to an abuse of process and are liable to be quashed.

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