Trisuns Chemical Industry v. Rajesh Agarwal

Facts

• A complaint of cheating was filed alleging that the accused induced the complainant to supply goods through false representations made from one city, while the goods were delivered in another city and payment was to be made in a third city.
• The accused challenged the jurisdiction of the court where the complaint was filed.
• The question was which court has territorial jurisdiction for a multi-location offence.

Issues

1. How is territorial jurisdiction determined where an offence involves acts at multiple locations?
2. Whether jurisdiction lies only where the initial false representation was made or also where its consequences were felt?

Held

• Under S.177-184 CrPC (S.211-218 BNSS), jurisdiction is determined by where the offence is committed.
• For offences that are composite (involving multiple essential acts at different places):
• Jurisdiction lies at any place where an essential ingredient of the offence occurred
• For cheating: both where the false representation was made AND where the victim was deceived/suffered loss
• The "cause of action" test applies: if any part of the cause of action arose within the court's limits, it has jurisdiction.

Ratio Decidendi

Territorial jurisdiction must be interpreted purposively to ensure that an accused cannot escape liability by fragmenting criminal acts across jurisdictions. Where an offence comprises multiple acts, any court where an essential ingredient occurs has competence.