Third-party impleadment in specific performance suits is proper where independent title claims may affect complete adjudication.

A third party claiming independent title and interest in immovable property may be impleaded as a defendant in a specific performance suit under Order I Rule 10(2) CPC when its presence is necessary for effective and complete adjudication. The applicant asserted ownership through a public auction purchase and disputed the plaintiff's agreement to sell as forged and ante-dated. Because excluding such a claimant could lead to truncated adjudication and multiplicity of proceedings, impleadment was upheld and the challenge to the order failed.

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Issues: Whether a third party claiming ownership and interest in the suit property could be impleaded as a defendant under Order I Rule 10(2) of the Code of Civil Procedure, 1908 in a suit for specific performance.

Analysis: The applicant asserted an independent claim to title over the property on the basis of a public auction purchase and alleged that the agreement to sell set up by the plaintiff was forged and ante-dated. In such circumstances, excluding the applicant would risk a truncated adjudication and multiplicity of proceedings. The presence of a person claiming right, title and interest in the very property in dispute was held to be necessary for effective and complete disposal of the suit.

Conclusion: Impleadment of the applicant as a defendant was upheld and the challenge to the impleadment order failed.

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