Territorial jurisdiction limits writ relief against ED proceedings when the impugned action and competent authorities lie outside the forum.

Territorial jurisdiction under Articles 226 and 227 depends on the situs of the impugned proceedings and the competent authority, not merely the petitioner's location or bank accounts. Where the challenge concerned ED action under the PMLA, with the predicate FIR registered at Mumbai and the seized material forwarded to Delhi, the Karnataka HC held that it lacked territorial jurisdiction to entertain the writ. The availability of an efficacious remedy before the appropriate forum with territorial nexus reinforced that the petition was not maintainable in Karnataka.

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Issues: (i) Whether the High Court had territorial jurisdiction under Articles 226 and 227 to entertain the writ petition challenging the ED proceedings arising from an FIR and seizure action connected to Mumbai and referred materials forwarded to Delhi.

Issue (i): Whether the High Court had territorial jurisdiction under Articles 226 and 227 to entertain the writ petition challenging the ED proceedings arising from an FIR and seizure action connected to Mumbai and referred materials forwarded to Delhi.

Analysis: The petition was founded on a challenge to the ED's action under Section 17 of the Prevention of Money Laundering Act, 2002, but the predicate FIR was registered at Mumbai and the seized material was forwarded to the Adjudicating Authority at Delhi. The Court accepted the respondents' objection that the relevant proceedings and authorities were outside Karnataka. It relied on the principle that territorial jurisdiction in criminal and related proceedings depends on the situs of the authority and the legally relevant forum, and not merely on the location of the petitioner or its bank accounts. The Court also noted that an efficacious remedy was available before the appropriate fora having territorial nexus.

Conclusion: The High Court had no territorial jurisdiction to grant the reliefs sought, and the challenge was not maintainable before it.

Final Conclusion: The writ petition could not be entertained in this forum and was liable to be rejected on jurisdictional grounds.

Ratio Decidendi: In proceedings seeking to quash or restrain criminal or enforcement action, the High Court will not entertain the writ where the impugned proceedings and the competent authorities are situated outside its territorial jurisdiction, particularly when an alternative efficacious remedy is available before the proper forum.

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