Lis pendens bars impleadment of pendente lite purchasers where they claim no independent right beyond the transferor.

Purchasers pendente lite in a suit for declaration of title based on an earlier registered will were not necessary or proper parties because they derived no independent legal footing beyond their transferors. Their purchase during the pendency of the suit attracted Section 52 of the Transfer of Property Act, so the alienation could not defeat the appellant's rights under the existing decree or justify their impleadment. A necessary party is one without whom complete adjudication is impossible, and a proper party is one whose presence is required for effective adjudication; on these facts, neither test was satisfied.

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Issues: Whether purchasers pendente lite were necessary or proper parties to a suit for declaration of title founded on an earlier registered will, and whether their impleadment was barred by the doctrine of lis pendens.

Analysis: The relief in the suit was traced to a registered will on which an earlier decree in favour of the appellant had already become final. The respondents purchased the property during the pendency of the second suit from persons deriving title through a party to the earlier litigation. Such purchasers could not challenge the legality or validity of the will, nor could they assert any independent right beyond the transferor's position. A necessary party is one without whom the dispute cannot be completely adjudicated, and a proper party is one whose presence is required for effective adjudication. On these facts, the respondents did not satisfy either description. The alienations made during the pendency of the suit were also subject to Section 52 of the Transfer of Property Act, and therefore could not affect the appellant's rights under the decree.

Conclusion: The respondents were neither necessary nor proper parties, and their impleadment was not justified.

Ratio Decidendi: A transferee pendente lite in a suit directly concerning immovable property is bound by Section 52 of the Transfer of Property Act and cannot be impleaded as a necessary or proper party where the transferee has no independent legal footing beyond the transferor's interest.

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