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Issues: Whether the Lokayukta was required to issue a pre-impleadment notice and hear the proposed parties before adding them to the proceedings suo motu.
Analysis: Rule 9 of the Goa Lokayukta Rules, 2012 permits the Lokayukta to add or delete parties at any stage, either suo motu or on application, and applies Order I Rule 10 of the Code of Civil Procedure, 1908 only as far as may be. The statutory scheme of the Goa Lokayukta Act, 2011 gives the Lokayukta power to conduct preliminary inquiry and detailed investigation, regulate its own procedure, and include persons whose presence is considered necessary for an effective and complete decision. Neither Rule 9 nor Order I Rule 10 expressly requires notice before impleadment. The principles of natural justice are flexible and must be applied contextually. A proposed party added later is not placed on a different procedural footing from a defendant initially impleaded, since objections to joinder can still be raised after impleadment.
Conclusion: Pre-impleadment notice was not mandatory, and the addition of the parties without prior notice did not violate natural justice.
Ratio Decidendi: Where the governing statute and rules permit suo motu addition of parties and do not expressly require prior notice, the court or tribunal may implead a necessary or proper party without pre-impleadment notice if the procedure remains fair and no prejudice is shown.