Joinder in writ petitions under Article 226 is permissible when petitioners share the same impugned action and common legal or factual questions.

Proceedings under Article 226 are treated as proceedings in a court of civil jurisdiction to the extent the Code of Civil Procedure can apply, so joinder principles are relevant. A joint writ petition is maintainable where the right to relief arises from the same act or transaction and a common question of law or fact exists, or where the petitioners are jointly interested in the cause of action. Where claims are separate and distinct, joinder is not maintainable. On the stated facts, both petitioners challenged the same order and common questions of law and fact arose, so a single writ petition could be filed.

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Issues: Whether two petitioners discharged by a single order could maintain one petition under Article 226 of the Constitution of India.

Analysis: Proceedings under Article 226 were held to be proceedings in a court of civil jurisdiction, so the procedure in the Code of Civil Procedure could be applied to the extent it was capable of application. On that basis, the rules governing joinder of plaintiffs were held relevant. The governing test is that a joint petition is maintainable where the right to relief arises from the same act or transaction and a common question of law or fact arises, or where the petitioners are jointly interested in the cause of action. Where claims are separate and distinct, a joint petition is not maintainable. On the facts, both petitioners were aggrieved by a single order and the same questions of law and fact arose.

Conclusion: A single petition was maintainable and the petitioners were entitled to join in one writ application.

Ratio Decidendi: A writ petition under Article 226 may be joined by multiple petitioners when the impugned action is common and the claim for relief arises from the same act or transaction with a common question of law or fact.

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