Proper party principles apply where landlords retain a direct legal interest in a demolition injunction suit.

A party is necessary or proper if its presence is needed for complete and effectual adjudication of the dispute. In a suit for perpetual injunction to restrain demolition of a demised building, landlords retaining right, title and interest in the property have a direct and substantial legal stake because demolition would affect those interests. Their interest is not merely commercial or evidentiary. The landlords were therefore proper parties, and their impleadment was correctly ordered.

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Issues: Whether the landlords were necessary or proper parties in a suit for perpetual injunction against the Municipal Corporation to restrain demolition of the demised building.

Analysis: A party is necessary or proper if his presence is required for complete and effectual adjudication of the dispute. Where a demolition notice is issued against a building in which the landlord retains right, title and interest, demolition would directly affect those interests. The landlord's interest is therefore not merely commercial or evidentiary but a direct and substantial legal interest in the subject-matter of the suit.

Conclusion: The landlords were proper parties and their impleadment was rightly ordered.

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