Territorial jurisdiction under Article 226 requires a real nexus to the impugned order; parallel proceedings justified refusal of writ relief.

For a writ under Article 226(2), territorial jurisdiction depends on whether the pleaded facts form a material and integral part of the cause of action with a real nexus to the impugned order. Here, a challenge to an impleadment order before the Competition Commission did not gain jurisdiction from alleged spillover effects in Tamil Nadu or investigation-related search and seizure, because those facts had no real connection with the order. The Court also applied forum conveniens and judicial comity: as the same impleadment order was already pending before the Delhi High Court, Delhi was the more appropriate forum and parallel proceedings risked conflicting outcomes. The writ petitions were dismissed as not maintainable in that Court.

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Issues: (i) whether any part of the cause of action arose within the territorial jurisdiction of the Court so as to invoke Article 226(2) of the Constitution of India; (ii) whether the Court should decline to entertain the petitions on the grounds of forum conveniens and comity of courts.

Issue (i): Whether any part of the cause of action arose within the territorial jurisdiction of the Court so as to invoke Article 226(2) of the Constitution of India.

Analysis: The challenge was only to a procedural order allowing impleadment of a party before the Competition Commission. The pleaded facts such as alleged spillover effect in Tamil Nadu, and the reference to search and seizure during investigation, were held to have no real nexus with the impugned impleadment order. The material facts necessary to sustain the writ petition did not constitute an integral part of the cause of action within the Court's jurisdiction.

Conclusion: No part of the cause of action sufficient to sustain territorial jurisdiction was made out.

Issue (ii): Whether the Court should decline to entertain the petitions on the grounds of forum conveniens and comity of courts.

Analysis: The same impleadment order had already been assailed before the Delhi High Court, which had taken cognizance of the dispute and reserved orders. In that situation, Delhi was the more convenient and natural forum, and entertaining the same challenge in another High Court risked conflicting decisions. The principles of forum conveniens and judicial comity therefore weighed against exercise of jurisdiction.

Conclusion: The Court declined to entertain the petitions on these grounds.

Final Conclusion: The writ petitions were not maintainable in this Court and were dismissed, leaving the parties to pursue remedies before the appropriate forum.

Ratio Decidendi: For a writ under Article 226(2), the pleaded facts must form a material and integral part of the cause of action with a real nexus to the impugned order, and even where some territorial connection exists, the High Court may decline jurisdiction where another forum is more appropriate or is already seized of the same matter.

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