Representative suit rights allow a reversioner to continue litigation when the original plaintiff seeks withdrawal.

A representative suit brought through the Collector on behalf of life tenants could not be terminated by withdrawal where reversioners were materially interested in the estate. The widows, suing under the Court of Wards framework, were treated as representing the entire estate, including future reversionary interests, so the court could add the reversioner as plaintiff to ensure the controversy was decided on merits. The reversioner was therefore entitled to continue the litigation, and the refusal to permit substitution was erroneous.

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Issues: Whether, in a representative suit instituted on behalf of life tenants through the Collector, a reversioner could be added as a plaintiff and allowed to continue the litigation when the Collector sought to withdraw the suit.

Analysis: The suit was treated as one of a representative character because the widows, though suing through the Collector under the Court of Wards Act, represented the entire estate, including the interests of the future reversioners. In such a suit, the original plaintiff could not, by withdrawing, put an end to the litigation where others were materially interested in the result. The reversioner had a direct interest in preserving the estate and, where the statutory route was inadequate, the Court could act on general principles to bring in the proper party so that the controversy might be decided on merits.

Conclusion: The reversioner was entitled to be added as a plaintiff and to continue the suit notwithstanding the Collector's withdrawal; the order refusing that course was erroneous.

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