State laws cannot confer special statutory jurisdiction on courts beyond the enacting State's territorial limits.

The first appellant is a religious society registered under the Societies Registration Act, 1860 (now governed by the Andhra Pradesh Societies Registration Act, 2001), with its registered office in Eluru, Andhra Pradesh, and its central working office in Pathanamthitta, Kerala

A dispute arose regarding the formation of the "IPC Malabar State" by bifurcating the existing Kerala State Council

Respondents 1 to 4 filed an Original Petition [O.P. (Society) No. 30/2025] before the District Court, Pathanamthitta, invoking Section 23 of the Andhra Pradesh Societies Registration Act, 2001 (the "Andhra Act")

The District Court passed an interim order on July 28, 2025, restraining the appellants from forming the sub-state or proceeding with its functions

The appellants challenged this order, primarily contending that a District Court in Kerala lacks the jurisdiction to entertain a petition filed under a specific provision of a State enactment from Andhra Pradesh

1. Whether a Principal Civil Court of original jurisdiction in the State of Kerala can entertain an original petition filed under Section 23 of the Andhra Pradesh Societies Registration Act, 2001

2. Whether the "doctrine of territorial nexus" can be invoked to extend the special jurisdiction conferred by a State statute to courts located outside that State's territorial limits

Article 245 of the Constitution of India, which restricts the legislative competence of a State Legislature to making laws "for the whole or any part of the State," unlike Parliament, which has extra-territorial legislative powers under Article 245(2)

Rajendra Diwan v. Pradeep Kumar Ranibala [(2019) 20 SCC 143], which established that State legislatures lack the competence to enact laws affecting the jurisdiction of courts outside their territory

Principles from Shrikant Bhalchandra Karulkar v. State of Gujarat [(1994) 5 SCC 459] regarding the "doctrine of territorial nexus," which requires a real connection between the State and the subject matter for a law to have intra-territorial validity

The Court observed that Section 23 of the Andhra Act provides a "special remedy" and designates a "designated forum" (the District Court) for disputes relating to societies registered in Andhra Pradesh

The Court reasoned that while the IPC operates in Kerala, the invocation of the District Court's jurisdiction in Pathanamthitta was based specifically on Section 23 of the Andhra Act, rather than a general civil suit under the Code of Civil Procedure

Applying Article 245, the Court held that a State law cannot confer special jurisdiction on a court situated beyond that State’s boundaries, as doing so would violate the federal structure of the Constitution

The Court rejected the respondents' reliance on Terapalli Dyvasahata Kumar v. S.M. Kantha Raju [(2018) 11 SCC 769], clarifying that the precedent dealt with which District Court within Andhra Pradesh had jurisdiction, not whether the Act applied to courts in other States

The Court determined that the doctrine of territorial nexus applies to the subject matter of legislation but cannot be used to empower a State to regulate the functioning or jurisdiction of courts in a different State

The Court set aside the impugned order dated July 28, 2025, and dismissed I.A. No. 4/2025. The appeal was allowed, with all other contentions on the merits of the church dispute left open