Territorial jurisdiction over tribunal transfer orders follows the Bench that issued the transfer, not the original service dispute cause of action.

Territorial jurisdiction to challenge a transfer order under Section 25 of the Administrative Tribunals Act depends on the location of the tribunal Bench that passed the transfer order, not on the original cause of action for the underlying service dispute. The cause of action for filing the original application under Section 19 is distinct from the cause of action arising from the transfer order itself. The broader Article 226(2) cause-of-action test cannot displace the constitutional rule governing scrutiny of tribunal decisions. Accordingly, the High Court at Calcutta lacked jurisdiction; the writ petition was dismissed, leaving the challenge open before the proper High Court.

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Issues: Whether the High Court within whose territorial jurisdiction the original application was filed could entertain a challenge to an order transferring that application under Section 25 of the Administrative Tribunals Act, 1985, or whether the challenge lies only before the High Court within whose territorial jurisdiction the Bench passing the transfer order is situated.

Analysis: The cause of action relevant to filing an original application under Section 19 of the Administrative Tribunals Act, 1985 is distinct from the cause of action arising from an independent transfer order passed under Section 25 of that Act. Territorial jurisdiction for judicial review of a transfer order must be determined with reference to the tribunal Bench that passed the transfer order, not with reference to the bundle of facts constituting the original cause of action for the service dispute. The Constitution Bench rule that all decisions of tribunals under Articles 323A and 323B are subject to scrutiny before a Division Bench of the High Court within whose jurisdiction the concerned tribunal falls controls the field, and the broader cause-of-action test under Article 226(2) cannot be used to confer jurisdiction on a different High Court. The transfer order in question was passed by the Principal Bench at New Delhi, which falls within the territorial jurisdiction of the High Court of Delhi.

Conclusion: The High Court at Calcutta lacked jurisdiction to entertain the writ petition challenging the transfer order under Section 25 of the Administrative Tribunals Act, 1985.

Final Conclusion: The impugned judgment was set aside, the writ petition before the High Court at Calcutta was dismissed, and the challenge to the transfer order was left open to be pursued before the jurisdictional High Court.

Ratio Decidendi: A challenge to an order transferring an original application under Section 25 of the Administrative Tribunals Act, 1985 lies only before the Division Bench of the High Court within whose territorial jurisdiction the tribunal Bench passing the transfer order is situated, and not before the High Court determined by the original cause of action for the underlying application.

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