Territorial jurisdiction in PMLA writ challenges depends on where the arrest, ECIR, remand, and alleged acts occurred.

Territorial jurisdiction to hear a writ challenging arrest and remand orders under PMLA turned on where the material events occurred and whether the alleged acts were confined to Himachal Pradesh. Because the arrest took place in New Delhi, the ECIR was registered there, and the remand and judicial custody orders were passed by the Special Court at Ghaziabad, while the alleged activity also extended to Uttar Pradesh, the dispute raised factual questions on place of commission and jurisdiction. Applying principles on offences spanning different local areas and act-consequence jurisdiction, the Himachal Pradesh High Court held that it could not entertain the challenge and that the petition was not maintainable before it.

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Issues: Whether the High Court had territorial jurisdiction to entertain the writ petition challenging the arrest and remand orders passed in connection with the PMLA proceedings.

Analysis: The arrest had been effected at New Delhi, the ECIR had been registered at New Delhi, and the subsequent remand and judicial custody orders were passed by the Special Court at Ghaziabad after the registration of the predicate FIR at Saharanpur and the filing of the PMLA complaint. The petitioner's alleged acts were not confined to Himachal Pradesh, since the materials showed activity in Uttar Pradesh as well, including acquisition and use of proceeds of crime, and the dispute as to the place of commission of the offence raised factual questions going to territorial jurisdiction. Applying the principles governing ordinary place of inquiry and trial, offences committed partly in different local areas, and offences where act and consequence arise in different jurisdictions, the Court held that the challenge to the arrest order could not be adjudicated in this writ petition before the Himachal Pradesh High Court.

Conclusion: The High Court lacked territorial jurisdiction to examine the challenge, and the petition was not maintainable before it.

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