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Pankajbhai Rameshbhai Zalavadiya vs Jethabhai Kalabhai Zalavadiya ... on 3 October, 2017

In Pankajbhai Rameshbhai Zalavadia (supra) an application for substitution filed under Order 22 Rule 4 was dismissed as not maintainable for the reason that defendant no.4 in the said suit had died even before the institution of the suit. The Supreme Court however found the heirs of the defendant to be necessary and proper party and therefore, held that even if Order 22 Rule 4 was not applicable, the court should have exercised power vested in it under Order 1 Rule 10 CPC. It was observed that mere mention of a wrong provision of law will not be impediment in the way of court in allowing impleadment if such power is vested under some other provision of law. The relevant observations made in this regard are as under:-
Supreme Court of India Cites 19 - Cited by 122 - M M Shantanagoudar - Full Document

Amit Kumar Shaw & Anr vs Farida Khatoon & Anr on 13 April, 2005

56. To the same effect is the decision of this Court in Amit Kumar Shaw v. Farida Khatoon (2005) 11 SCC 403 wherein this Court held that a transferor pendente lite may not even defend the title properly as he has no interest in the same or may collude with the plaintiff in which case the interest of the purchaser pendente lite will be ignored. To avoid such situations the transferee pendente lite can be added as a party defendant to the case provided his interest is substantial and not just peripheral. This is particularly so where the transferee pendente lite acquires interest in the entire estate that forms the subject matter of the dispute. This Court observed:
Supreme Court of India Cites 3 - Cited by 394 - A R Lakshmanan - Full Document
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