Territorial jurisdiction under Article 226 depends on forum conveniens, not merely a minor cause of action or headquarters presence.

Territorial jurisdiction under Article 226 was examined in light of the doctrine of forum conveniens. The Court found that the grievance arose mainly from events in Uttar Pradesh, where the appellant resided and the examinations were to be conducted, so the mere presence of the respondent in Delhi and reliance on affiliation bye-laws did not by themselves make Delhi the proper forum. It held that a small or incidental part of the cause of action does not automatically confer jurisdiction, and a jurisdiction clause cannot override the forum conveniens inquiry where no direct impugned action in Delhi is shown. The writ appeal was therefore not entertained in Delhi.

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Issues: Whether the Delhi High Court should exercise territorial jurisdiction in the writ appeal, or decline it on the ground that the more appropriate forum lay elsewhere applying the doctrine of forum conveniens.

Analysis: The grievance arose substantially from the conduct of the school in Uttar Pradesh, where the appellant resided and where the relevant examinations were to be conducted. The mere presence of CBSE in Delhi, or the reliance on the affiliation bye-laws conferring jurisdiction on Delhi, did not by itself make Delhi the proper forum. The Court applied the settled principle that a small or incidental part of the cause of action does not automatically confer jurisdiction under Article 226, and that the convenience of the parties and the appropriateness of the forum must also be considered. Reading the jurisdiction clause purposively, the Court held that it could not override the doctrine of forum conveniens where no direct impugned action of CBSE in Delhi was shown.

Conclusion: The Court declined to exercise territorial jurisdiction and held that the writ appeal did not merit interference.

Ratio Decidendi: Under Article 226, territorial jurisdiction is not established merely by the presence of a minuscule part of the cause of action or the respondent's headquarters within the forum State; the Court must also be satisfied that it is the forum conveniens, and a contractual or bye-law jurisdiction clause cannot displace that inquiry where the substantive cause of action lies elsewhere.

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