Issues Involved: 1. Territorial jurisdiction of a High Court to entertain a writ petition under Article 226 of the Constitution of India. 2. Determination of cause of action in relation to territorial jurisdiction. 3. Relevance of the situs of the office of the respondents in determining jurisdiction. 4. Application of the doctrine of forum conveniens.
Issue-wise Detailed Analysis:
1. Territorial Jurisdiction of a High Court to Entertain a Writ Petition Under Article 226 of the Constitution of India: The primary issue in this appeal was whether the seat of the Parliament or the Legislature of a State would be a relevant factor for determining the territorial jurisdiction of a High Court to entertain a writ petition under Article 226 of the Constitution of India. The appellant's writ petition was dismissed by the Delhi High Court on the ground of lack of territorial jurisdiction.
2. Determination of Cause of Action in Relation to Territorial Jurisdiction: The cause of action is crucial in determining the jurisdiction. It implies a right to sue and encompasses all material facts necessary for the plaintiff to prove to support their right to the judgment. Clause (2) of Article 226 of the Constitution of India allows High Courts to issue directions, orders, or writs to any Government, authority, or person within its territorial jurisdiction if the cause of action, wholly or in part, arises within those territories. The Supreme Court emphasized that even a small fraction of the cause of action arising within the jurisdiction of the Court would suffice to confer jurisdiction.
3. Relevance of the Situs of the Office of the Respondents in Determining Jurisdiction: The Court held that the mere location of the Union of India's seat in Delhi does not confer jurisdiction on the Delhi High Court to entertain a writ petition questioning the constitutionality of a Parliamentary Act. The situs of the office of the Parliament or the authority in power to make subordinate legislation or issue a notification does not by itself constitute a cause of action. The Court referred to several precedents, including the case of Abdul Kafi Khan v. Union of India, which held that the situs of the Union of India in Delhi does not confer jurisdiction on the Delhi High Court.
4. Application of the Doctrine of Forum Conveniens: The Court noted that even if a small part of the cause of action arises within the territorial jurisdiction of the High Court, it may not be a determinative factor compelling the High Court to decide the matter on merit. The Court may refuse to exercise its discretionary jurisdiction by invoking the doctrine of forum conveniens. This doctrine allows the Court to consider the convenience of the forum in deciding whether to entertain the matter.
Conclusion: The Supreme Court concluded that the Delhi High Court was correct in dismissing the writ petition on the ground of lack of territorial jurisdiction. The appeal was dismissed accordingly, with no costs awarded. The judgment clarified that the situs of the Parliament or the Legislature of a State does not confer jurisdiction on the High Court to entertain a writ petition unless a part of the cause of action arises within its territorial jurisdiction.
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