Territorial jurisdiction under Article 226(2) turns on integral cause of action, not merely incidental communications received locally.

Territorial jurisdiction under Article 226(2) depends on where the cause of action, wholly or in part, actually arises. In the tender matter discussed, the material events occurred at Bombay: the notice, bid submission, document scrutiny, fire tests and impugned communication. Communications received at Nagpur, including a corrigendum, opening date and certificate query, were only incidental and did not form an integral part of the cause of action. The writ petition was therefore not maintainable before the Nagpur Bench and was to be presented before the Principal Seat at Bombay.

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Issues: Whether the petition could be entertained by the Nagpur Bench of the Bombay High Court when the material events constituting the cause of action arose at Bombay and only certain communications were received at Nagpur.

Analysis: Territorial jurisdiction under Article 226(2) of the Constitution depends on whether the cause of action, wholly or in part, arises within the relevant territorial limits. Section 41 of the Bombay Reorganization Act, 1960 and Rule 1 of Chapter XXXI of the Bombay High Court Appellate Side Rules, 1960 delimit the matters to be presented and heard at Nagpur in administrative and territorial terms. The tender notice, submission of bids, scrutiny of documents, fire tests and issuance of the impugned letter all occurred at Bombay. The receipt at Nagpur of communications relating to the tender, including the corrigendum, opening date and certificate query, did not constitute any part of the cause of action.

Conclusion: The petition was not maintainable before the Nagpur Bench and could not be entertained there.

Final Conclusion: The writ petition was returned for presentation before the Principal Seat at Bombay because no part of the cause of action arose within the territorial jurisdiction of the Nagpur Bench.

Ratio Decidendi: Mere receipt of incidental communications within a Bench's territorial limits does not confer jurisdiction unless they form an integral part of the cause of action under Article 226(2) as read with the applicable territorial allocation provisions.

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