A DRT's location does not confer territorial jurisdiction if the entire cause of action arises elsewhere.

The petitioner-company, registered in Delhi, availed a loan of ₹172.50 Crores from the Saharanpur branch (U.P.) of Central Bank of India.

Following financial losses, the account was declared a Non-Performing Asset (NPA) on 15.10.2024, and the Bank issued a demand notice under Section 13(2) of the SARFAESI Act, 2002.

Despite objections filed under Section 13(3A), the Bank issued a possession notice under Section 13(4).

The petitioner challenged this before the Debts Recovery Tribunal (DRT), Dehradun, which observed on 17.09.2025 that the Bank failed to decide the objections before proceeding.

While a regular appeal was filed before the DRAT, Allahabad, the Bank simultaneously initiated proceedings under Section 14 of the Act before the Additional District Magistrate (ADM), Saharanpur, to take physical possession.

The petitioner approached the Uttarakhand High Court to quash the Section 14 proceedings.

1. Whether the High Court of Uttarakhand has the territorial jurisdiction to entertain the writ petition merely because the underlying order was passed by the DRT Dehradun, even though the loan, assets, and parties are situated in Uttar Pradesh?

Article 226(2) of the Constitution of India, which empowers a High Court to issue writs if the cause of action, wholly or in part, arises within its territorial jurisdiction.

The Court noted that "cause of action" for Article 226(2) carries the same meaning as under Section 20(c) of the Code of Civil Procedure (CPC), defined as the "bundle of facts" necessary for a party to prove to succeed.

Jurisdiction is contingent upon the location of the cause of action rather than the seat of the authority alone, as established in Nawal Kishore Sharma vs. Union of India (2014) and Navinchandra N. Majithia vs. State of Maharashtra (2000).

The Court analyzed the "bundle of facts" constituting the cause of action, identifying them as the lending of money and the subsequent default by the petitioner.

It found that these transactions occurred exclusively in Saharanpur, Uttar Pradesh.

The Court rejected the petitioner's argument that the DRT Dehradun's order conferred jurisdiction, clarifying that while DRT Dehradun’s territorial remit includes parts of Uttar Pradesh, its physical location in Uttarakhand does not transplant the cause of action of a U.P.-based dispute into the jurisdiction of the Uttarakhand High Court.

Since the secured assets, the lending branch, and the respondent ADM are all located in Saharanpur (U.P.), no part of the cause of action arose within the State of Uttarakhand.

The Court ruled that the mere passing of an order by a Tribunal located in Uttarakhand does not confer jurisdiction if the underlying facts of the case pertain to another state.

Consequently, the writ petition was dismissed in limine.