Territorial jurisdiction under Article 226(2) depends on integral facts only; mere service of an order is not enough.

For territorial jurisdiction under Article 226(2), only material and integral facts forming the basis of the grievance constitute the cause of action. Mere service of an order within the forum State may make the order effective and give rise to a right of action, but it does not by itself create territorial jurisdiction. In service matters, once an appellate authority passes an order, the original order merges in the appellate order, so the relevant cause of action arises from the making of the appellate order, not from its receipt. The contrary view treating service as part of the cause of action was stated to be inconsistent with settled law and was overruled.

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Issues: Whether a writ petition under Article 226(2) of the Constitution of India is maintainable in the High Court merely because an order made outside its territorial jurisdiction was served on the petitioner within the State, and whether such service forms part of the cause of action.

Analysis: Cause of action under Article 226(2) must consist of the material and integral facts on which the relief depends. Communication or service of an order may make the order effective and may give rise to a right of action, but it does not by itself constitute an integral part of the cause of action. In service matters, once an appellate authority passes an order, the original order merges in the appellate order, and the relevant cause of action arises from the making of the appellate order, not from its receipt by the employee. The earlier view treating service of dismissal orders as part of the cause of action was found inconsistent with the settled law on territorial jurisdiction and with the controlling principles laid down by the Supreme Court.

Conclusion: Service of the impugned order within the State does not confer territorial jurisdiction, and the earlier contrary view was overruled.

Final Conclusion: The challenge to maintainability failed, the writ appeal succeeded, and the connected writ petitions were dismissed for want of territorial jurisdiction.

Ratio Decidendi: For the purpose of Article 226(2), territorial jurisdiction is attracted only by facts that are material and integral to the grievance; mere service of an order within the forum State creates only a right of action, not a part of the cause of action.

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