Territorial jurisdiction in writs depends on the integral cause of action; parallel filing was treated as forum shopping.

Territorial jurisdiction under Article 226(2) turns on whether an integral part of the cause of action arose within the Court's limits, not on a merely incidental connection. Where the relevant banking communications, settlement proposals and the earlier challenge to the fraud classification were all tied to the New Delhi branch and had already been litigated before the Delhi High Court, the later writ in Bombay was treated as forum shopping. Applying forum conveniens and judicial propriety, the Court held that the Delhi High Court was the proper forum and declined to entertain the petition, while granting liberty to approach the Delhi High Court.

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Issues: Whether the High Court had territorial jurisdiction to entertain the writ petition and whether the petition was liable to be dismissed for forum shopping in view of the earlier proceedings before the Delhi High Court.

Analysis: Under Article 226(2) of the Constitution of India, territorial jurisdiction depends on whether the cause of action, wholly or in part, arises within the Court's territorial limits. The governing test is not the presence of a superficial or incidental link, but whether an integral part of the cause of action has arisen within jurisdiction. Applying that principle, the relevant banking communications, settlement proposals, and the earlier challenge to the fraud classification were all connected with the New Delhi branch and had already been litigated before the Delhi High Court. Since the integral part of the controversy had already been invoked there, the later writ in this Court amounted to choosing a different forum for the same dispute. Judicial propriety and the doctrine of forum conveniens therefore pointed to the Delhi High Court as the proper forum.

Conclusion: The High Court held that it lacked the appropriate territorial forum to entertain the writ petition and that the petition was an instance of forum shopping. The petition was therefore dismissed, with liberty to approach the Delhi High Court.

Ratio Decidendi: In writ jurisdiction, territorial competence must be tested by the situs of the integral cause of action and forum conveniens; where the material facts and earlier proceedings are anchored to another High Court, the later petition should not be entertained in a different forum.

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