Amendment and impleadment in tortious interference suits were upheld to resolve the real controversy and ensure complete adjudication.

Amendment of the plaint and prayer clause was upheld because it arose from subsequent events, reflected the controversy already pleaded, and did not alter the suit's basic character; the court applied the test of necessity for deciding the real controversy and absence of irremediable prejudice, and permitted the amendments to avoid multiplicity of proceedings. Impleadment of Walchandnagar Industries Ltd. was also sustained because the pleaded case alleged its direct role in the attempted substitution of the plaintiffs and the amended reliefs were claimed against it, making it a necessary party for complete adjudication. The court distinguished impleadment principles in specific performance suits as inapplicable.

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Issues: (i) whether the amendment of the plaint and the consequential amendment of the prayer clause should be permitted; (ii) whether Walchandnagar Industries Ltd. was a necessary party and could be impleaded in the suits.

Issue (i): whether the amendment of the plaint and the consequential amendment of the prayer clause should be permitted.

Analysis: The amendments arose from subsequent events and from material already pleaded in the suits, which alleged that the principal defendant was attempting to substitute the plaintiffs with a third party. The proposed additions did not fundamentally change the character of the suits, which were founded on alleged tortious interference with the plaintiffs' contractual rights. The proper test for amendment is whether it is necessary for deciding the real controversy and whether it causes irreparable prejudice. In the circumstances, permitting the amended pleadings and prayers was necessary to enable a complete adjudication and to avoid multiplicity of proceedings.

Conclusion: The amendment of the plaint and the consequential amendment of the prayer clause were rightly allowed, and the challenge to that part of the order failed.

Issue (ii): whether Walchandnagar Industries Ltd. was a necessary party and could be impleaded in the suits.

Analysis: The suits themselves alleged a concerted effort to replace the plaintiffs with the proposed third party, and the amended reliefs directly claimed against that party. In a suit of this nature, the alleged co-conspirator and beneficiary was a proper and necessary party for an effective and complete adjudication. The principles governing impleadment in suits for specific performance of immovable property were held to be inapplicable because the controversy here concerned alleged tortious interference and substitution in an ongoing project.

Conclusion: The impleadment of Walchandnagar Industries Ltd. was justified and the challenge to that part of the order failed.

Final Conclusion: The appeals lacked merit, and the order allowing amendment and impleadment was upheld in full.

Ratio Decidendi: An amendment that brings on record subsequent events and is necessary for deciding the real controversy should be allowed if it does not fundamentally alter the suit or cause irremediable prejudice, and a person directly implicated in the pleaded controversy and against whom relief is claimed may be impleaded as a necessary party for complete adjudication.

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