Territorial jurisdiction under Article 226 requires a material cause of action; mere receipt of a letter does not confer it.

Territorial jurisdiction under Article 226 depends on whether the facts relied on are material, integral, and essential to the cause of action for the relief claimed. Mere receipt or service of a communication within the court's limits does not by itself confer jurisdiction unless that fact must be pleaded and proved for the writ. Here, the arbitrator was appointed at New Delhi and the arbitral orders were made at Mumbai; the petitioners' receipt in Kolkata of the appointment letter and later communications was only informational and not an essential part of the challenge. The High Court therefore held that it lacked territorial jurisdiction and the writ petition was not maintainable.

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Issues: Whether service of the impugned letters on the petitioners at Kolkata constituted a part of the cause of action so as to confer territorial jurisdiction on the High Court under Article 226 of the Constitution of India.

Analysis: Territorial jurisdiction under Article 226 depends on whether the facts relied on are material, integral, or essential to the lis. Mere receipt or service of a communication does not by itself create jurisdiction unless the fact of such service is necessary to plead and prove for obtaining the relief sought. The appointment of the arbitrator was made at New Delhi, and the arbitral orders were made at Mumbai. The receipt in Kolkata of the appointment letter and subsequent communications did not form an integral part of the cause of action for challenging the appointment and the continuation of the arbitral proceedings. Those communications only informed the petitioners of already taken actions and did not constitute essential facts on which the writ petition depended.

Conclusion: The High Court had no territorial jurisdiction to entertain the writ petition.

Final Conclusion: The writ petition was not maintainable in the High Court and was dismissed for want of territorial jurisdiction.

Ratio Decidendi: A communication received within the court's territorial limits does not confer jurisdiction under Article 226 unless its service is a material and integral fact necessary to the cause of action for the relief claimed.

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