Court Rules That Recruitment Stages Conducted in Rajasthan Constitute Integral Part of Cause of Action, Rejecting Union of India's Objection on Jurisdiction
In a significant judgment dated September 25, 2026, the Rajasthan High Court (Division Bench, Jaipur Bench) dismissed the Union of India's appeals challenging the territorial jurisdiction of the Court in matters concerning a pan-India recruitment process. The case, Union of India v. Sunil Kumar, involved several writ petitions filed by candidates from Rajasthan who had participated in a recruitment drive conducted by the Union of India for the post of Constable Driver in the Sashastra Seema Bal (SSB).
The recruitment process, initiated through an advertisement dated July 28, 2020, was pan-India and involved multiple stages including Physical Efficiency Test/Physical Standard Test (PET/PST), computer tests, trade tests, and medical examinations conducted across different states - notably PET/PST and computer tests in Rajasthan, trade tests in Bihar, and medical examinations in New Delhi.
The candidates, residents of Rajasthan, contended that the Rajasthan High Court had jurisdiction because crucial stages of the recruitment, such as PET/PST and computer tests, were conducted within the state and these stages formed an integral part of the cause of action. The Union of India argued that since the final impugned order emanated from outside Rajasthan, the High Court lacked territorial jurisdiction.
The Court analyzed Article 226(2) of the Constitution of India, which empowers any High Court to entertain writ petitions if the cause of action, wholly or in part, arises within its territorial jurisdiction, regardless of where the respondent authority is situated. The Division Bench, comprising Chief Justice Mr. Sanjay K. Agrawal and Justice Inderjeet Singh, relied on settled Supreme Court precedents including Nawal Kishore Sharma v. Union of India (2014), Kusum Ingots & Alloys Ltd. v. Union of India (2004), and Shanti Devi Alias Shanti Mishra v. Union of India (2020).
The Court held that the recruitment process was composite and inter-connected, and the material stages conducted in Rajasthan were sufficient to constitute a fraction of the cause of action arising within the state. It further emphasized that the candidates were permanent residents of Rajasthan and had performed key recruitment activities such as filling the online application, downloading admit cards, and undergoing tests in Rajasthan, which established a strong nexus with the State.
Additionally, the Court applied the principle of forum conveniens, observing that requiring the candidates to approach distant High Courts would cause unnecessary hardship and expense. Therefore, the Rajasthan High Court was not only territorially competent but also the most appropriate forum for adjudicating the disputes.
Rejecting the Union of India's preliminary objection, the Court upheld the order of the Single Judge dismissing the challenge to territorial jurisdiction. The appeals were dismissed with parties bearing their own costs.
This judgment reinforces the principle that even a small but material fraction of cause of action arising within a High Court's jurisdiction suffices to confer writ jurisdiction under Article 226(2). It also underscores the courts' sensitivity to convenience and hardship faced by litigants in multi-state recruitment matters.
Bottom Line:
Constitution of India, 1950 Article 226(2) Territorial jurisdiction - In a pan-India recruitment process, where material stages such as PET/PST and computer test were conducted in Rajasthan and candidates participated from Rajasthan, such facts constitute integral part of cause of action - Rajasthan High Court has territorial jurisdiction and is also a convenient forum - Preliminary objection of Union of India rightly rejected.
Statutory provision(s):
Constitution of India, 1950 Article 226(2)
Union of India v. Sunil Kumar, (Rajasthan)(DB)(Jaipur Bench) : Law Finder Doc Id # 2992827
