Impleadment of transferees under Order I Rule 10 CPC depends on effective adjudication and avoidance of multiplicity.

Order I Rule 10 CPC permits impleadment where a person's presence is necessary for complete adjudication and to avoid multiplicity of proceedings. The text addresses purchasers of undivided shares who were alleged to have bought in breach of an injunction, raising questions on the vendor's binding obligation and whether the transferees were bona fide purchasers for value in good faith. Those issues had to be examined to determine whether their presence was required in the suit or impleadment proceedings. The purchasers were treated as proper and necessary parties, and the challenge to their impleadment was rejected.

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Issues: Whether purchasers of undivided shares in the suit property, whose purchases were alleged to have been made in breach of an injunction order, were proper and necessary parties entitled to be impleaded in the suit.

Analysis: Order I Rule 10 of the Code of Civil Procedure, 1908 permits addition of a party whose presence is necessary to enable the Court to effectively and completely adjudicate upon and settle all questions involved in the suit. The provision is also directed to preventing multiplicity of proceedings. On the facts, there was a dispute whether the vendor was bound by the injunction and whether the purchasers were bona fide transferees for value in good faith. Those questions had to be decided either in the suit or in the impleadment application itself. If impleadment were refused without addressing them, a separate suit would likely follow, leading to multiplicity of litigation. The Court distinguished the earlier precedent relied on by the appellant because, on its facts, there was no basis to deny impleadment to the purchasers in the present case.

Conclusion: The purchasers were rightly treated as proper and necessary parties and their impleadment was upheld.

Final Conclusion: The challenge to the impleadment orders failed, and the appeal was dismissed, with the Court also deprecating the practice of impleading judicial officers as respondents in such proceedings.

Ratio Decidendi: A transferee whose presence is required for an effective adjudication of the dispute, especially where adjudication of the validity and effect of the transfer is necessary to avoid multiplicity of proceedings, may be impleaded under Order I Rule 10 of the Code of Civil Procedure, 1908.

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