Article 226 territorial jurisdiction requires cause of action or respondent presence, not merely service of detention order or residence.

Territorial jurisdiction under Article 226 depends on whether the respondent authority is within the court's territorial limits or whether a part of the cause of action arose there. Mere service of a detention order or the petitioner's residence in the forum State does not by itself confer jurisdiction. Applying that principle to a habeas corpus challenge to a detention order issued in Maharashtra, with the detention, arrest, bail proceedings and related events all arising in Mumbai, the Punjab and Haryana High Court found that no part of the cause of action arose within its territorial limits and therefore lacked jurisdiction to entertain the petition.

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Issues: Whether the High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain a habeas corpus petition challenging a detention order passed by the Government of Maharashtra under Section 3(1) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974.

Analysis: Territorial jurisdiction under Article 226 depends on the location or residence of the person or authority against whom relief is sought and on whether any part of the cause of action arose within the Court's territorial limits. The place where an order may have effect on the petitioner, or the petitioner's asserted residence, does not by itself confer jurisdiction. On the facts, the detention order was passed in Maharashtra, the underlying events, arrest, bail proceedings and connected proceedings all arose in Mumbai, and no part of the cause of action arose within the territorial limits of the Punjab and Haryana High Court.

Conclusion: The High Court lacked territorial jurisdiction to entertain the petition.

Ratio Decidendi: For a writ under Article 226, jurisdiction lies only where the respondent authority is within the Court's territorial limits or where a part of the cause of action arises there; mere service of the order or the petitioner's residence within the forum State does not confer jurisdiction.

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