All Necessary Parties Must Be Heard to Reach the Truth in Legal Disputes — Supreme Court Emphasized Comprehensive Representation in Property Litigation

Constitution of India, 1950 (COI) — Civil Procedure Code, 1908 (CPC) — Order XXII Rule 5 — Order I Rule 10(2) — Determination of Legal Representative — Impleadment of Necessary Parties — Declaration and Recovery of Possession — Property Dispute

a) The Supreme Court upheld the High Court’s decision allowing the impleadment of Respondent No. 1, the daughter of the deceased plaintiff, as a party-defendant in a property dispute. (Para 12)

b) The Court emphasized that the entire purpose of a trial is to reach the truth of the matter, making it essential that all necessary parties must be heard before a decision is rendered. (Para 12)

c) The Appellant’s contention that the substitution of the plaintiff excluded the right of other legal heirs to contest the suit was deemed baseless and unsupported by law. (Para 11)

The Supreme Court dismissed the appeal, affirming the lower courts’ decisions and holding that all necessary parties must be heard for a just determination of property disputes.

Subjects: Impleadment — Legal Representative — Property Dispute — Necessary Parties — Substitution — Declaration — Recovery of Possession — Will — Title Dispute — Civil Suit

Nature of the Litigation: Civil Appeal arising from a dispute over the substitution and impleadment of legal heirs in a property suit.

Relief Sought: Appellant sought reversal of the High Court’s order allowing the impleadment of Respondent No. 1 as a defendant.

Reason for Filing: Appellant challenged the impleadment on the grounds that his substitution as the sole plaintiff excluded the right of other legal heirs to contest the suit.

Prior Decisions: Trial Court and High Court both ruled in favor of Respondent No. 1’s impleadment, citing the need for comprehensive representation.

Issues: Whether the impleadment of Respondent No. 1 as a party-defendant was legally justified.

Submissions/Arguments: Appellant contended that his substitution as the plaintiff under a registered will precluded the necessity of including other legal heirs. Respondent No. 1 alleged the will was forged and sought to protect her interests in the disputed property.

Ratio: The Court held that the trial process aims to uncover the truth, which necessitates the participation of all interested parties, especially in cases involving contested wills and property claims. (Para 12)