Associations lack locus standi to pursue writ petitions claiming service benefits for members.

The petitioner, Airports Authority of India Pensioners Forum, represented its President and claimed to espouse the grievances of its members regarding the alleged non-grant of pension under the Central Civil Services (Pension) Rules, 1972, and the continued payment of pension under the Employees’ Pension Scheme. The Forum sought directions to the Airports Authority of India to release the capitalisation amount and issue Pension Payment Orders, to grant provisional pension, to stop EPF pension payments, and to calculate and pay pension arrears after adjustment of amounts received under the EPS.

The Forum’s members were stated to be retired employees from different States across India; details of 15 members from different States were furnished in the petition.

The respondents objected that the petition was not maintainable because the Forum had no personal grievance, the dispute concerned service benefits, and the individual affected pensioners had not been impleaded. They further contended that no part of the cause of action arose within Kerala, as the members had worked and retired outside the State.

1. Whether the Kerala High Court had territorial jurisdiction under Article 226(2) of the Constitution to entertain a writ petition concerning pensionary benefits of members who had worked and retired outside Kerala, merely because the petitioner Forum had its registered address in Kerala.

2. Whether an association or pensioners’ forum could maintain a writ petition seeking service and pensionary benefits on behalf of its members, without the individual aggrieved pensioners being joined as petitioners.

The Court applied Article 226(2) of the Constitution, under which a High Court may exercise writ jurisdiction only where the cause of action arises wholly or in part within its territorial jurisdiction.

Relying principally on Oil and Natural Gas Commission v. Utpal Kumar Basu and the Full Bench decision in Nakul Deo Singh v. Deputy Commandant, the Court held that jurisdiction must be determined from the material facts constituting the cause of action, and that mere receipt of a communication or residence within the State is insufficient.

The Court further relied on Anand Anoop v. Union of India, The Registrar, Indian Maritime University v. Dr. K.G. Viswanathan, Dental Council of India v. Viswanath, Aparna Balan v. Union of India and ILA Rajeev (Minor) v. National Institute of Design for the principle that a right of action is distinct from a cause of action and that the situs of a central authority or its nationwide powers does not confer jurisdiction on every High Court.

On locus standi, the Court applied Vinoy Kumar v. State of U.P., Tancem Marketing Employees’ Welfare Union v. Secretary to Government, Neetu v. State of Punjab, Paradip Port Trust Officer Pensioners’ Association v. Union of India and All India BSNL Pensioners’ Welfare Association v. Union of India, holding that an association ordinarily cannot maintain a writ petition to claim individual service or pensionary benefits for its members unless an applicable exception, such as genuine public interest litigation or inability of the affected persons to approach the Court, is established.

The Court found that the Forum’s members belonged to different States and had rendered service and retired outside Kerala. The substantive grievance concerned the grant of pensionary and other service benefits arising from their employment with the Airports Authority of India, not any act occurring within Kerala.

The Forum’s Kerala address, by itself, was not a fact constituting the cause of action, and the nationwide jurisdiction of the respondent authorities could not confer territorial jurisdiction on every High Court.

Independently, the Court held that the Forum was not personally affected by the impugned action and was attempting to litigate individual service claims on behalf of members who had not been impleaded as petitioners.

The authorities cited by the petitioner did not establish that an association could maintain such a petition; some did not consider maintainability, while others concerned broader public-law or public-interest issues rather than individual pension claims.

No substantive relief or directions concerning pension, provisional pension, EPF payments, or arrears were granted.