Necessary party impleadment in specific performance suits upheld where prior purchaser held title by registered sale deed.

A proposed purchaser was held to be a necessary party in a suit for specific performance and injunction where the property had already been transferred to him by registered sale deed before the suit was filed. Because the plaintiff had also originally impleaded him, his presence was considered necessary for effective adjudication and to avoid multiplicity of proceedings. The trial court's order allowing impleadment under Order 1 Rule 10 was therefore sustained, and the revision challenge failed.

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Issues: Whether the proposed purchaser was rightly impleaded as a defendant under Order 1 Rule 10 in a suit for specific performance and injunction.

Analysis: The property had been sold before institution of the suit to the proposed defendant under a registered sale deed, and the plaintiff had himself originally impleaded him as a party. In these circumstances, his presence was found necessary for effective adjudication of the dispute and to avoid multiplicity of proceedings.

Conclusion: The impleadment was upheld and the revision challenge to the trial court's order failed.

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