Territorial jurisdiction under Article 226 may be refused where only a minimal cause of action arises and another forum is more appropriate.

A High Court exercising Article 226 jurisdiction may decline to entertain a writ petition where only an insignificant part of the cause of action arose within its territory and the dispute is substantially connected to another forum. The court applied the doctrine of forum non conveniens, noting that the loan transaction, mortgaged property, alleged natural calamity loss, restructuring request, and impugned action were all situated outside Delhi. A minimal territorial link was insufficient to make Delhi the proper forum, and the discretionary writ jurisdiction was therefore not required to be exercised. The petitioner was directed to approach the appropriate forum.

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Issues: Whether the writ petition should be entertained by the Delhi High Court when only a small part of the cause of action arose within its territory and the substantial events had occurred within the jurisdiction of another High Court.

Analysis: The petition invoked Article 226 of the Constitution of India, but the material events connected with the dispute, including the loan transaction, the mortgaged property, the alleged loss caused by natural calamity, the restructuring request, and the impugned action, were situated outside Delhi. The mere existence of some connection with Delhi did not make it the forum conveniens. In applying the doctrine of forum non conveniens, the Court held that territorial jurisdiction under Article 226 is not compelled merely because a fraction of the cause of action arises within its limits. The substance of the matter and the existence of a more appropriate forum are relevant, and a High Court may decline to exercise discretionary writ jurisdiction where the nexus with its territory is only minuscule.

Conclusion: The Court declined to entertain the writ petition and held that the petitioner should approach the appropriate forum.

Ratio Decidendi: Under Article 226, a High Court may refuse to entertain a writ petition where only an insignificant part of the cause of action arises within its jurisdiction and the dispute is more appropriately tried in another forum, applying the doctrine of forum non conveniens.

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