Unregistered agreement for sale does not make a third party a necessary or proper party in Section 7 insolvency proceedings.

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....In Section 7 insolvency proceedings, intervention by a third party is not warranted merely because it claims an interest under an unregistered agreement for sale. The Appellate Tribunal held that Order I Rule 10 CPC principles may guide, but do not directly govern, the Code; the relevant inquiry is whether the person is a necessary or proper party to adjudication of the financial creditor's claim against the corporate debtor on default. Because the appellant held no conveyance and its claim, if any, lay only against the corporate debtor, it had no legal status requiring impleadment. The refusal to intervene was upheld.....