Territorial jurisdiction in writ petitions requires a real causal nexus; incidental presence of the authority in Delhi was insufficient.

Territorial jurisdiction in writ proceedings depends on the substance of the lis and the dominant material facts giving rise to the grievance; the mere presence of the respondent authority within Delhi was not enough where the search, seizure, investigation, and related proceedings were centred at Gurugram. The Court held that the essential and integral part of the cause of action had arisen outside Delhi, and that a small incidental connection within jurisdiction did not require the petition to be entertained when forum conveniens pointed elsewhere. The petition was therefore dismissed for want of territorial nexus, with liberty to approach the jurisdictional High Court.

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Issues: Whether the petition was entertainable in the Delhi High Court when the material, essential and integral part of the cause of action had arisen outside its territorial jurisdiction and the Court was asked to exercise discretionary writ jurisdiction.

Analysis: The reliefs challenged search and seizure actions conducted at Gurugram, the petitioners resided there, the investigation and related proceedings were based there, and the mere presence of the respondent authority in Delhi did not by itself create a sufficient territorial nexus. The governing principle is that the Court must examine the substance of the lis and the dominant, material facts giving rise to the grievance, and that even a small part of cause of action within jurisdiction does not compel entertainment of the petition where forum conveniens points elsewhere. The Court therefore found that the foundational events and legal injury were substantially connected to Gurugram and not Delhi.

Conclusion: The petition was not entertainable in Delhi and was dismissed, with liberty to approach the jurisdictional High Court.

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