The court emphasized that jurisdiction under Article 226(2) requires a significant part of the cause of action to arise within the High Court's territorial limits for a writ petition to be maintained.

Judgment :

HARISH TANDON, CJ.

1. A preliminary objection is raised in the instant writ petition on the maintainability thereof before this Court on the premise of non-accrual of even minuscule part of the cause of action, within the territorial limits of this Court.

2. The relevant facts discerned from the instant writ petition constituting a cause of action are succinctly jotted down hereunder.

The opposite party No.1, Security Printing and Minting Corporation of India Limited having its office at New Delhi, floated a tender on 17^th September, 2020 for Designing, Development and Configuration of EPF, PF and Pension Trust in SAP, wherein the petitioner participated and was awarded the contract vide Letter of Intent dated 2^nd November, 2020. Subsequently, the purchase order was issued on 28^th November, 2020 after furnishing the performance Bank Guarantee. Three show-cause notices were issued on 5^th February 2021, 16^th March 2021 and 11^th January, 2022 respectively to blacklist the petitioner for delay in completing the project. The petitioner replied to the said show-cause notices taking shelter under unprecedented COVID-19 pandemic causing severe constraint in mobilising the resources, health disruptions and the Government- imposed lockdowns together with updating the progress having made in the interregnum and sought for an extension of time. Several mails were exchanged seeking cooperation to complete the minor pending items and even the extended Bank Guarantee was also furnished. It is averred that the moment the project was at the verge of completion leaving the minuscule part to be completed, the Debarment Notification dated 18^th June, 2025 was uploaded on the official website of the said opposite party No.1 purporting to debar the petitioner for two years. The said letter of debarment is assailed in the instant writ petition and a plea of maintainability of the writ petition by this Court assumes significance in relation to the exercise of the power and the jurisdiction enshrined under Article 226 of the Constitution of India.

3. Apart from the oral submissions advanced by the counsel appearing for the writ petitioner, the written note of submission is also submitted in this regard. It is sought to be contended by the counsel that although the contract was executed at Delhi but was substantially performed through the Bhubaneswar office by deployment of the workforce in execution of the contract. It is further submitted that all the operational, administrative and logistic supports essential for performance of the contract were in fact mobilised from Bhubaneswar and, thus, a part of the cause action has arisen within the territorial limits of this High Court and, therefore, the writ petition is maintainable. The reliance is placed upon the judgments of the apex Court delivered in case of Kusum Ingots & Alloys Ltd. v. Union of India reported in (2004) 6 SCC 254 and Alchemist Ltd. v. State Bank of Sikkim reported in (2007) 11 SCC 335 in support of the contention that if the cause action has arisen within the territorial limits of a different High Court, the writ petition filed in any one of the High Courts is maintainable.

4. At the very outset, we must record that there is no dissention so far as the law laid down in the above noted decisions. There is no incongruity or any dissent to the proposition of law that a minuscule part of the cause of action would be the relevant factor to exercise the power under Article 226 of the Constitution of India having arisen within i