Territorial jurisdiction and Internal Complaints Committee validity turned on cause of action links and statutory member qualifications.

Territorial jurisdiction under Article 226 exists where the pleaded facts show a direct nexus with the relief sought and a part of the cause of action arises within the court's territory; on that basis, Delhi was held to have jurisdiction because the employer's Delhi office, the common Internal Complaints Committee, and the alleged coercion in Delhi formed part of the cause of action. The Internal Complaints Committee was also found to be invalidly constituted because the external member did not meet the statutory qualification under the sexual harassment law, and Rule 4 was treated as applicable only to the Local Complaints Committee. Its proceedings and report were therefore set aside, and the inquiry had to be conducted afresh by a properly reconstituted committee.

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Issues: (i) Whether the Delhi High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain the writ petition; (ii) Whether the Internal Complaints Committee constituted by the employer complied with Section 4(2)(c) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

Issue (i): Whether the Delhi High Court had territorial jurisdiction under Article 226 of the Constitution of India to entertain the writ petition.

Analysis: Jurisdiction under Article 226 is attracted where the seat of the respondent is within the territory or where the cause of action, wholly or in part, arises there. The facts pleaded and relied upon included the employer's registered office in Delhi, the constitution of a common Internal Complaints Committee for Delhi and Gurgaon, and the allegation that the resignation was coerced in Delhi. These facts were held to have a direct nexus with the reliefs sought and to constitute part of the cause of action within Delhi.

Conclusion: The objection to territorial jurisdiction was rejected and the Court held that it had jurisdiction to entertain the writ petition.

Issue (ii): Whether the Internal Complaints Committee constituted by the employer complied with Section 4(2)(c) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

Analysis: Section 4(2)(c) requires an Internal Complaints Committee member who is from a non-governmental organisation or association committed to the cause of women, or otherwise a person familiar with issues relating to sexual harassment. Rule 4 of the 2013 Rules was held to apply to the Local Complaints Committee and not to the Internal Complaints Committee. On the material before the Court, the appointed external member did not satisfy the statutory qualification, and the object of the provision to ensure independence and impartiality would be defeated by a contrary view.

Conclusion: The Committee was held to be invalidly constituted and its proceedings and report were set aside.

Final Conclusion: The dismissal for want of territorial jurisdiction was overturned, and the employer was directed to reconstitute the Internal Complaints Committee in accordance with law and conduct the inquiry afresh.

Ratio Decidendi: For a writ petition under Article 226, a High Court has jurisdiction when the pleaded facts bear a direct nexus to the reliefs claimed and constitute part of the cause of action within its territory; and an Internal Complaints Committee must be constituted strictly in accordance with Section 4(2)(c), with the external member satisfying the statutory requirement of independence and subject-specific familiarity.

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