Impleadment of third parties requires a direct, subsisting interest and necessity for complete adjudication of the suit.

A third party may be impleaded only if its presence is necessary for complete and effectual adjudication of the real controversy and it has a direct, subsisting legal or equitable interest in the subject matter. A mere commercial, contingent, or future-litigational interest is insufficient. On that test, the plaintiff's vendor had no direct nexus with the reliefs claimed and the suit issues could be decided without its presence, so impleadment was not justified under Order 1 Rule 10(2) CPC.

---

---

Issues: Whether the vendor of the plaintiff was a proper party to be impleaded under Order 1 Rule 10(2) of the Code of Civil Procedure, 1908.

Analysis: A person can be added as a party only if his presence is necessary for the complete and effectual adjudication of the real controversy in the suit. The required interest must be direct, subsisting, and cognisable in law, and not a mere commercial or contingent interest. The desire to avoid possible future litigation is not enough unless the proposed addition would enable the Court to decide the questions arising in the suit itself. Since the plaintiff's vendor had no direct nexus with the reliefs sought and no issue in the suits could not be decided without him, his impleadment was not justified.

Conclusion: The vendor was not a proper party and could not be impleaded under Order 1 Rule 10(2) of the Code of Civil Procedure, 1908.

Ratio Decidendi: A third party can be impleaded only when his presence is necessary to adjudicate the real controversy in the suit and he has a direct, subsisting legal or equitable interest in the subject-matter.

---