Territorial jurisdiction under Article 226 extends to challenges against Railway Board action issued from New Delhi and related cause of action.

Article 226(1) gives territorial jurisdiction where the respondent authority is located within the High Court's limits, while Article 226(2) additionally permits jurisdiction where the cause of action arises wholly or partly within the territory. The text explains that Article 226(2) is supplemental, not a substitute for Article 226(1). It further notes that a challenge to paragraph 1744 of the Indian Railways Commercial Manual could sustain jurisdiction because the Railway Board issued it from New Delhi and the writ would run against an authority situated there. Forum convenience can operate only where jurisdiction already exists and cannot defeat jurisdiction on the pleaded facts.

---

---

Issues: Whether the Delhi High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain writ petitions challenging punitive freight demands raised by railway authorities and paragraph 1744 of the Indian Railways Commercial Manual.

Analysis: Article 226(1) confers jurisdiction on the High Court where the person, authority, or Government to whom the writ is directed is located within its territorial limits. Article 226(2) enlarges that jurisdiction by enabling a High Court to act where the cause of action, wholly or in part, arises within its territory. The decision distinguishes these two sources of power and holds that Article 226(2) is supplemental, not substitutive, of Article 226(1). The mere fact that the demands were raised outside Delhi would not by itself exclude jurisdiction if the challenge also lay to paragraph 1744 of the Indian Railways Commercial Manual, which was issued by the Railway Board at New Delhi and against which the writ would run to an authority situated within Delhi. The doctrine of forum convenience was held to operate only where jurisdiction otherwise exists and could not defeat jurisdiction in the absence of a competing competent forum on the facts pleaded.

Conclusion: The Court held that it had territorial jurisdiction to entertain the writ petitions.

---