Antecedent commercial transactions and communications from a registered office do not confer territorial jurisdiction under Article 226(2).

The Petitioner, a Karnataka Government undertaking, imported natural river sand during 2017 to address a state-wide shortage

It executed a global tender and agreement in Bengaluru with M/s Poseidon FZE

Poseidon engaged Vishwasamudra for logistics, which in turn contracted with Respondent No. 2 (Adani Krishnapatnam Port Ltd.) in Andhra Pradesh for port services

A dispute arose when Respondent No. 2 asserted a lien over the sand cargo lying at its port in Andhra Pradesh due to unpaid dues by Vishwasamudra and issued an auction notice dated 06.08.2024

The Petitioner challenged this notice before the Karnataka High Court, claiming ownership

Respondent No. 2 raised a preliminary objection regarding territorial jurisdiction

1. Whether the Karnataka High Court has territorial jurisdiction under Article 226(2) of the Constitution of India to entertain the writ petition when the impugned auction and the subject property are located in Andhra Pradesh

Article 226(2) of the Constitution of India, which mandates that a High Court may exercise jurisdiction if the cause of action, wholly or in part, arises within its territories

Union of India v. Adani Exports Ltd. (2002), which established that only facts having a direct nexus/relevance to the lis constitute a cause of action

ONGC v. Utpal Kumar Basu (1994), holding that the mere location of a petitioner’s office or antecedent events (like tenders) do not confer jurisdiction if the material dispute arose elsewhere

Distinction made with Nawal Kishore Sharma v. Union of India (2014) and Navinchandran N. Majithia v. State of Maharashtra (2000), where integral parts of the cause of action were found to have occurred within the jurisdiction

The Court identified that the core lis was the legality of the auction notice issued by the Port in Andhra Pradesh

It reasoned that "cause of action" refers to material, essential, and integral facts, not incidental or antecedent ones

The Court found that while the Petitioner’s internal tender process and agreement with Poseidon occurred in Bengaluru, these were merely "factual backdrops"

Every material event constituting the dispute—the service agreement between the Port and the agent, the accrual of dues, the storage of cargo, the assertion of a lien, and the proposed auction—occurred exclusively at Krishnapatnam Port in Andhra Pradesh

The Court rejected the argument that receiving communications in Bengaluru or suffering commercial consequences there conferred jurisdiction, stating that such an interpretation would render the limitations of Article 226(2) "otiose"

The Writ Petition was dismissed as not maintainable, with liberty reserved for the Petitioner to approach the competent forum in Andhra Pradesh, with all contentions on merits kept open