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        Case ID :

        2025 (6) TMI 1516 - HC - SEBI

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        Territorial jurisdiction under Article 226 requires an integral cause of action; peripheral Delhi links did not suffice here. Under Article 226(2), territorial jurisdiction exists only where the pleaded facts forming part of the cause of action are material, essential, and ...
                        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                          Provisions expressly mentioned in the judgment/order text.

                            Territorial jurisdiction under Article 226 requires an integral cause of action; peripheral Delhi links did not suffice here.

                            Under Article 226(2), territorial jurisdiction exists only where the pleaded facts forming part of the cause of action are material, essential, and integral to the relief sought. Peripheral facts such as a petitioner's registered office in Delhi, receipt of communications there, or access to online notices do not by themselves confer jurisdiction. Where the impugned circular and notices were issued from Mumbai and the alleged arbitrariness and breach of natural justice arose there, the cause of action was held to lie outside Delhi. The writ petition was therefore dismissed for lack of territorial jurisdiction, with liberty to approach the appropriate High Court.




                            Issues: Whether the High Court had territorial jurisdiction under Article 226 to entertain the writ petition challenging the impugned circular and notices issued by the stock exchange.

                            Analysis: For territorial jurisdiction under Article 226(2), the pleaded facts must constitute a material, essential, or integral part of the cause of action and must have a nexus with the relief sought. Facts that are merely incidental, such as the petitioner company's registered office, receipt of communications at Delhi, access of website notices at Delhi, or circulation of videos elsewhere, do not by themselves confer jurisdiction unless they are integral to the challenge. The impugned circular and notices were issued from Mumbai, the complained-of omissions and commissions occurred there, and the core challenge related to the alleged arbitrariness and lack of natural justice in their issuance and implementation. Those facts were found to arise in Mumbai and not in Delhi.

                            Conclusion: The High Court lacked territorial jurisdiction to entertain the petition, and the writ petition was dismissed with liberty to approach the jurisdictional High Court.

                            Final Conclusion: Territorial jurisdiction could not be founded on peripheral or consequential facts when the substantive cause of action arose outside the Court's territorial limits.

                            Ratio Decidendi: Under Article 226(2), only those pleaded facts that are material, essential, and integral to the relief sought can constitute part of the cause of action for territorial jurisdiction.


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