Territorial jurisdiction under Article 226(2) is not created by mere communication of an order at the petitioner's residence.

Territorial jurisdiction under Article 226(2) arises only when an integral part of the cause of action occurs within the High Court's territory, and the material facts relied on must have a direct nexus with the relief claimed. Mere residence of the petitioner, or mere communication of dismissal, appellate, or revisional orders at the place of residence, does not by itself create a fresh cause of action. The Allahabad HC read the earlier Full Bench and Division Bench rulings as consistent with this principle, and treated Nawal Kishore Sharma as fact-specific. It found no real conflict requiring Larger Bench reference and reaffirmed the challenged view.

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Issues: Whether the earlier decisions holding that mere communication of dismissal, appellate or revisional orders at the employee's place of residence does not confer territorial jurisdiction remain good law in view of the Supreme Court's decision in Nawal Kishore Sharma; and whether there was any conflict requiring reference to a Larger Bench on the question of territorial jurisdiction under Article 226(2) of the Constitution of India.

Analysis: Territorial jurisdiction under Article 226(2) depends on whether the cause of action, wholly or in part, arises within the Court's territory. The material facts relied upon must be integral to the lis and must have a direct nexus with the relief claimed. Mere residence of the petitioner, or mere service/communication of the appellate or revisional order at the place of residence, does not by itself create a fresh cause of action. The earlier Full Bench and Division Bench decisions were read as consistent with this settled principle. The decision in Nawal Kishore Sharma was held to turn on its own peculiar facts, where the legal injury and the relevant communications were closely connected with the forum territory. No true conflict was found between the prior decisions and the later Division Bench rulings.

Conclusion: The reference was answered in the negative. The Court held that there was no conflict of opinion warranting Larger Bench consideration, and the challenged view that mere communication of the orders at the place of residence does not confer territorial jurisdiction was reaffirmed.

Ratio Decidendi: Territorial jurisdiction under Article 226(2) is conferred only when an integral part of the cause of action arises within the territory of the High Court, and mere communication of an order at the petitioner's place of residence, without more, does not create such jurisdiction.

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