Territorial jurisdiction in writ proceedings may arise on communication of a reclassification demand that forms part of the cause of action.

Territorial jurisdiction in a writ petition can arise where an impugned reclassification order and duty demand are communicated to, and received at, the petitioner's office within the forum State, because receipt of the order or notice forms an integral part of the cause of action. Although the reclassification decision and higher-duty levy were taken outside the jurisdiction, their operative effect arose on communication to the petitioner at Calcutta. Authorities cited against jurisdiction were distinguished on their facts, and a later departmental clarification treating the product under the lower-duty classification also removed the underlying grievance. On these facts, the writ petition was maintainable in Calcutta.

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Issues: Whether this Court had territorial jurisdiction to entertain the writ petition on the footing that the impugned reclassification letter and demand were received at the petitioner's Calcutta office and thus gave rise to part cause of action within the jurisdiction of this Court.

Analysis: The impugned decision to reclassify the product and levy higher duty was taken in Rajasthan, but the order became operative only when it was communicated to the petitioner. The envelope and correspondence showed receipt at the Calcutta head office, and the demand for higher excise duty was thereby enforced against the petitioner within the jurisdiction of this Court. Receipt of the order or notice was therefore an integral part of the cause of action. The authorities cited against jurisdiction were distinguished on the ground that, on the facts, no part of the cause of action had arisen there. The subsequent departmental clarification, treating the product as falling under the lower-duty classification, also removed the underlying grievance.

Conclusion: Territorial jurisdiction existed in favour of the petitioner, and the writ petition was maintainable.

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