Impleadment in oppression and mismanagement proceedings fails where asset purchasers are strangers and civil title issues lie elsewhere.

In oppression and mismanagement proceedings, strangers to the company are not ordinarily necessary parties unless their presence is required to resolve the internal dispute. A purchaser of company assets was held not to be impleaded where the assets had already been sold before the company petition was filed, the sale deed was already under challenge in civil court, and the tribunal could not determine civil rights arising from that transaction within its limited jurisdiction. An allegation based on a later status quo order also failed because the transfer had preceded that order. The impleadment application was therefore not maintainable at that stage and was rejected.

---

---

Issues: Whether proposed respondents purchasing the company's assets could be impleaded as parties in a company petition alleging oppression and mismanagement, and whether such impleadment was maintainable at that stage.

Analysis: The petition was under the oppression and mismanagement jurisdiction, where disputes ordinarily lie between shareholders and management. The proposed respondents were strangers to the company and were not shown to be necessary parties to adjudicate the internal dispute. The assets had been sold before the company petition was first filed, and the petitioner's challenge to the sale deed was already pending before the civil court. The Tribunal noted that it could not decide the civil rights concerning the sale transaction within its limited jurisdiction. It also noted that the allegation against the later purchaser based on a status quo order could not stand because the assets had already been transferred before that order was passed.

Conclusion: The impleadment application was not maintainable at that stage and was rejected.

---