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U.P. Awas Evam Vikas Parishad vs Gyan Devi (Dead) By L.Rs. And Ors on 20 October, 1994

18. In order to appreciate the issues raised in the present review petitions, it will be necessary to consider that there is distinction between non-joinder of necessary party who ought to have been joined, and non-joinder of a person who is joined only as a matter of convenience or expediency. This is because Order I Rule 9 is rule of procedure which does not affect the substantive law. It has been held in U.P. Awas Evam Vikas Parishad v. Gyan Devi, (1995) 2 SCC 326 at page 343
Supreme Court of India Cites 61 - Cited by 306 - S C Agrawal - Full Document

Udit Narain Singh Malpaharia vs Additional Member, Board Of Revenue, ... on 19 October, 1962

21. The law is well settled that a necessary party is one without whom no order can be made effectively and a proper party is one in whose absence an effective order can be made but whose presence is necessary for a complete and final decision of the question involved in the proceeding. (See Udit Narain Singh Malpaharia v. Additional Member, Board of Revenue [1963 Supp (1) SCR 676 : AIR 1963 SC 786] .)
Supreme Court of India Cites 4 - Cited by 470 - Full Document
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