A. Code of Civil Procedure, 1908 (V of 1908), Order 1 Rule 10 – Impleadment as party -- For impleading a person as a party, two conditions must be satisfied: firstly, that there must be a right to some relief against such person in respect of the controversies involved in the proceedings; and secondly, that no effective decree can be passed in the absence of such person -- Power under Order 1 Rule 10 CPC is discretionary and should be exercised sparingly but to advance the cause of complete justice and to avoid multiplicity of proceedings.

(Para 16)

B. Code of Civil Procedure, 1908 (V of 1908), Order 1 Rule 10 – Impleadment as party – Suit for declaration and permanent injunction -- Applicant placed on record Mutations and Jamabandi for the year 1996-97 showing transfer of the suit land from the State Government to ‘J’ and thereafter to himself -- Several rounds of litigation, including writ petitions before the High Court, in which his alleged rights over the same land have been contested -- These materials were sufficient to give the trial court a prima facie basis to conclude that the applicant has at least an arguable interest in the subject matter of the suit and that his presence would facilitate complete adjudication of the dispute.

(Para 2, 16)

C. Code of Civil Procedure, 1908 (V of 1908), Order 1 Rule 10 – Impleadment as party – Suit for declaration and permanent injunction -- Objection as to claim based upon fraudulent documents – It is a matter of evidence which cannot be conclusively determined at the stage of impleadment -- Impleadment order does not confer any legitimacy upon applicant’s title; it merely allows him to be heard so that the court's final decree, if passed, may bind all persons claiming interest in the property and avoid future litigation -- Apprehension that the impleadment will prejudice the plaintiff/ petitioner's rights is thus unfounded.

(Para 2, 17)

D. Code of Civil Procedure, 1908 (V of 1908), Order 1 Rule 10 – Impleadment as party – Suit for declaration and permanent injunction --Dominus litis – Argument as to Plaintiff/ Petitioner, being dominus litis, is free to choose his defendants, cannot prevail when the relief claimed directly affects third-party rights reflected in the public records -- Petitioner's suit seeks declaration of nullity of a rapat entry and correction of revenue records may have an impact upon any person claiming interest through existing entries or documents.

(Para 2, 18)