Territorial jurisdiction over a corporation depends on Section 20 CPC; contractual warranty terms and office correspondence did not create Delhi jurisdiction.

Territorial jurisdiction over a corporation is governed by Section 20 of the Code of Civil Procedure, 1908: the suit may be filed at the corporation's principal place of business or where the cause of action arises and it has a subordinate office. A transfer of the former Lahore office to New Delhi, or correspondence stating that the claim would be examined by the New Delhi office, did not by itself create jurisdiction in Delhi or amount to a cause of action there. A contractual warranty clause could not override the statutory jurisdictional requirements. The Delhi courts were therefore held to lack territorial jurisdiction, and the jurisdictional objection was upheld.

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Issues: Whether the Delhi courts had territorial jurisdiction to try the suit against the corporation in view of the contractual warranty clause and the applicable rule under Section 20 of the Code of Civil Procedure, 1908.

Analysis: The governing principle was that the place of suing for a corporation is determined by Section 20 of the Code of Civil Procedure, 1908, under which the corporation may be sued at its principal place of business, or at a place where the cause of action arises and it has a subordinate office. The shifting of the former Lahore office to New Delhi, or correspondence indicating that the claim would be looked into by the New Delhi office, did not by itself transfer jurisdiction or create a cause of action at Delhi. The contractual clause also did not displace the statutory rule where the statutory conditions for jurisdiction were not satisfied.

Conclusion: The Delhi courts lacked territorial jurisdiction, and the objection to jurisdiction was rightly upheld in revision in favour of the petitioner.

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