Territorial jurisdiction under customs law turns on where the offence is completed, not where later search or seizure occurs.

Delhi court lacked territorial jurisdiction over the Customs Act offence because the offence was complete when the vehicles were intercepted outside Delhi and the contraband was only then. Taking the vehicles and accused to Delhi for search did not shift the place of commission, so Section 177 CrPC governed and Section 179 CrPC did not apply because no intended consequence ensued in Delhi. A complaint filed before a court without territorial jurisdiction was therefore returned under Section 201 CrPC.

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Issues: Whether the Delhi court had territorial jurisdiction to try the offence under Section 135(1)(b) of the Customs Act, 1962 when the trucks were intercepted outside Delhi but the search and seizure were conducted in Delhi.

Analysis: The offence was treated as complete when the vehicles were intercepted on reliable information and the contraband came to light at that stage. The subsequent act of taking the vehicles and accused to Delhi for search did not shift the place of commission to Delhi. Section 177 of the Code of Criminal Procedure, 1973 requires trial by the court within whose local jurisdiction the offence was committed, and Section 179 did not apply because the intended consequence in Delhi never actually ensued after the interception at Matheri and Kurukshetra. Since the complaint was filed before a court lacking territorial jurisdiction, returning the complaint under Section 201 of the Code of Criminal Procedure, 1973 was .

Conclusion: The Delhi court lacked territorial jurisdiction, and the order returning the complaint was .

Ratio Decidendi: For offences under the Customs Act, territorial jurisdiction is determined by the place where the offence is completed, and a forum cannot be created merely by taking the accused or vehicle to another place for search or seizure after interception.

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