Territorial jurisdiction in pre-execution preventive detention challenges depends on where the cause of action actually arises, not mere apprehension of arrest.

Territorial jurisdiction under Article 226(2) depends on whether the cause of action, wholly or in part, arose within the Court's territory. In a pre-execution challenge to a preventive detention order issued by the Government of Gujarat, the High Court held that a mere apprehension of arrest at Indore did not form an integral part of the cause of action. The detention order was made at Gandhinagar, the seizure and related criminal proceedings were outside the State, and no material showed any part of the cause of action within the Court's territorial limits. The Court therefore lacked territorial jurisdiction and declined to entertain the writ petition.

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Issues: Whether the High Court had territorial jurisdiction under Article 226(2) of the Constitution of India to entertain a writ petition challenging a preventive detention order passed by the Government of Gujarat when the order was not yet executed and the alleged apprehension of arrest was at Indore.

Analysis: The petition was filed at the pre-execution stage and the detention order had not yet been served. The Court held that territorial jurisdiction depends on whether the cause of action, wholly or in part, arose within its territory. It distinguished authorities dealing with anticipatory bail and held that apprehension of arrest or possible execution of the detention order at Indore did not constitute an integral part of the cause of action for quashing the detention order. The impugned order was passed by the Government of Gujarat at Gandhinagar, the seizure and criminal proceedings were also outside the State, and no material showed any part of the cause of action within the territorial limits of the Court.

Conclusion: The Court held that it lacked territorial jurisdiction and refused to entertain the petition.

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