Territorial jurisdiction under Article 226(2) depends on an integral cause of action, not incidental local facts.

Article 226(2) confers writ jurisdiction only where the whole or part of the cause of action arises within the High Court's territory, and the pleaded facts must form an integral part of the lis with a real nexus to the relief sought. Facts that are merely incidental, such as receipt of communications, local business activity, or earlier unrelated proceedings, do not by themselves create territorial jurisdiction. On the pleadings, the impugned conciliation, its termination, and the reference to arbitration arose outside the territorial limits, so the local facts were neither material nor germane to the writ petition. The High Court therefore lacked territorial jurisdiction to entertain it, and the refusal to do so was upheld.

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Issues: Territorial jurisdiction of the High Court under Article 226(2) of the Constitution of India was in question, namely whether any material, essential or integral part of the cause of action arose within its territory so as to entertain the writ petition.

Analysis: Article 226(2) permits exercise of writ jurisdiction where the cause of action, wholly or in part, arises within the territorial jurisdiction of the High Court. The governing test is whether the pleaded facts constitute an integral part of the cause of action and have a nexus with the lis. Facts that are merely incidental, such as receipt of communications, business operations within the forum, or earlier proceedings unconnected with the impugned action, do not by themselves confer territorial jurisdiction. On the pleadings, the impugned conciliation, termination thereof, and reference to arbitration all arose outside the Court's territorial limits, and the asserted local facts were held to be neither material nor germane to the relief claimed.

Conclusion: The High Court lacked territorial jurisdiction to entertain the writ petition, and the refusal to entertain it was upheld.

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