Territorial jurisdiction under Article 226 depends on where the cause of action arises, not merely the respondent's head office location.

Territorial jurisdiction under Article 226 depends on whether the cause of action, wholly or in part, arises within the court's territorial limits, and the mere location of the respondent's head office in Delhi does not by itself confer jurisdiction when the material events, injury, and alleged acts arose elsewhere. The expression "cause of action" for Article 226(2) is to be understood consistently with Section 20(c) CPC. Where the grievance substantially arises in another State and an efficacious remedy is available before the competent High Court there, the writ court may decline jurisdiction on forum conveniens. The writ petition was held not maintainable before the Delhi High Court for want of territorial jurisdiction.

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Issues: Whether the writ petition was maintainable before the Delhi High Court in the absence of territorial jurisdiction.

Analysis: Territorial jurisdiction under Article 226 depends on whether the cause of action, wholly or in part, arises within the Court's territorial limits. The mere location of the respondent's head office in Delhi does not by itself confer jurisdiction when the alleged acts, injury, and material events arise elsewhere. The expression "cause of action" for Article 226(2) is to be understood in the same sense as under Section 20(c) of the Code of Civil Procedure, 1908. Where the grievance substantially arises in another State and an efficacious remedy is available before the competent High Court there, the writ court may also decline to exercise jurisdiction on the principle of forum conveniens.

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

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