Territorial jurisdiction under Article 226 requires a material cause of action, not merely an office location or policy decision site.

Territorial jurisdiction under Article 226 depends on a real and material cause of action with a nexus to the relief sought. The mere location of the corporate office, or the place where an administrative decision or circular was issued, does not by itself confer jurisdiction if the decision is to be implemented elsewhere. Because the petitioners worked at Noida and the relief would operate there, the Delhi High Court held that no material cause of action arose within Delhi. Section 27 of the National Capital Region Planning Board Act, 1985 gives the Act overriding effect but does not alter the law on territorial jurisdiction or deem cause of action to arise in Delhi merely because Noida is within the NCR.

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Issues: Whether the Delhi High Court had territorial jurisdiction to entertain the writ petition on the basis of the location of the corporate office, the place where the policy decision was taken, or Section 27 of the National Capital Region Planning Board Act, 1985.

Analysis: Jurisdiction under Article 226 depends on the existence of a real and material cause of action within the Court's territory. Facts that have no nexus with the relief claimed do not confer jurisdiction, and the mere situs of the office making a decision or issuing a circular does not by itself create territorial jurisdiction when the decision is to be implemented elsewhere. The petitioners were employed and working at Noida, and the relief sought would operate there. Section 27 of the National Capital Region Planning Board Act, 1985 gives the Act overriding effect but does not alter the law governing territorial jurisdiction or deem cause of action to arise in Delhi merely because Noida falls within the National Capital Region.

Conclusion: The Delhi High Court lacked territorial jurisdiction and the writ petition was not maintainable.

Final Conclusion: The petition failed on the threshold issue of jurisdiction and was dismissed with costs.

Ratio Decidendi: Territorial jurisdiction under Article 226 is attracted only by facts constituting a material cause of action with a nexus to the relief sought, and not by the mere location of the authority's office or the place where an administrative decision was taken.

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