Territorial jurisdiction in customs seizure disputes turns on where the integral cause of action arose, not where goods were purchased.

Territorial jurisdiction under Article 226(2) depends on where the integral facts giving rise to the impugned action occurred. In a challenge to customs seizure and confiscation, the relevant cause of action arose from interception and seizure of the goods, the confiscation order, and service of that order, all at Ahmedabad. Purchase of the television at Madras and its despatch from Madras were not integral parts of the cause of action for the customs action. On that basis, no part of the cause of action arose within Madras, and the writ petition was not maintainable in the Madras High Court.

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Issues: Whether the writ petition was maintainable before the Madras High Court under Article 226(2) of the Constitution of India on the ground that part of the cause of action arose at Madras.

Analysis: The expression "cause of action" denotes the bundle of facts that must be proved for relief. In a challenge to customs seizure and confiscation, the material facts were the interception and seizure of the goods at Ahmedabad, the confiscation order passed by the authority at Ahmedabad, and the service of that order there. The purchase of the television at Madras and its despatch from Madras were held not to form an integral part of the cause of action for the impugned customs action. Since the seizure, confiscation, and penalty proceedings all arose from events occurring at Ahmedabad, no part of the cause of action arose within Madras.

Conclusion: The writ petition was not maintainable in the Madras High Court for want of territorial jurisdiction.

Final Conclusion: The writ appeal was allowed solely on the ground that the High Court lacked territorial jurisdiction to entertain the writ petition, leaving the parties to pursue remedies before the appropriate court at Ahmedabad.

Ratio Decidendi: For a challenge to customs seizure and confiscation, territorial jurisdiction under Article 226(2) depends on where the integral facts giving rise to the impugned action occurred, and purchase or despatch of the goods from another place does not by itself constitute part of the cause of action.

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