Lis pendens and impleadment discretion limit a transferee pendente lite's right to join pending property litigation.

A transferee pendente lite who purchased suit property during long-pending litigation without leave of court is bound by lis pendens under section 52 of the Transfer of Property Act and has no absolute right to be impleaded or to seek amendment of the pleadings. While such a transferee may be joined to protect an interest in the property, impleadment is discretionary and not automatic. The trial court's refusal was sustained because it gave cogent reasons, including the absence of prior leave and the apparent risk of delay and complication in the pending suits. The revisional court was justified in declining interference.

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Issues: Whether a transferee pendente lite, who purchased the suit property without leave of court during the pendency of long-pending suits, was entitled as of right to be impleaded as a party and to seek amendment of the pleadings.

Analysis: A transferee pendente lite is bound by the doctrine of lis pendens under section 52 of the Transfer of Property Act and does not acquire an absolute right to intervene in pending litigation. Although such a transferee may ordinarily be joined to protect his interest, impleadment is not automatic in every case. The trial court had recorded cogent reasons for refusal, including the long pendency of the suits, the absence of leave of court before the transfer, and the apparent attempt to complicate and delay the proceedings. The revisional court was therefore justified in declining interference, as the orders of the trial court reflected a proper exercise of discretion.

Conclusion: The transferee pendente lite was not entitled as of right to impleadment or amendment, and the refusal to add her as a party was upheld against the appellant.

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