Territorial jurisdiction under Article 226(2) requires an integral cause of action; mere residence or receipt of orders is insufficient.

Territorial jurisdiction under Article 226(2) depends on whether an essential and integral part of the cause of action arose within the Court's limits. Here, the impugned disciplinary orders were issued by authorities in Assam and West Bengal, so the material events giving rise to the grievance arose outside Bihar. The petitioner's residence in Bihar and receipt of the orders there were held to be only remote or incidental connections and not enough to found jurisdiction. On that basis, the writ petition was found not maintainable for want of territorial jurisdiction and was rejected.

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Issues: Whether the writ petition was maintainable before the High Court on the basis of territorial jurisdiction under Article 226(2) of the Constitution of India.

Analysis: The impugned disciplinary orders were passed by authorities located in Assam and West Bengal. The petitioner's residence in Bihar and the fact of communication of orders to him in Bihar were held not to constitute an integral part of the cause of action. The pleadings disclosed that the material events giving rise to the grievance arose outside the territorial jurisdiction of the Court, and mere residence or correspondence from Bihar could not confer jurisdiction. The Court applied the settled principle that only those facts which are essential and integral to the right to relief can found territorial jurisdiction, and rejected the invocation of jurisdiction based on a remote or incidental connection.

Conclusion: The writ petition was not maintainable for want of territorial jurisdiction and was rejected.

Ratio Decidendi: For territorial jurisdiction under Article 226(2), only an integral part of the cause of action can confer jurisdiction, and mere residence of the petitioner or receipt of orders within the State is insufficient.

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