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The presence of opposing parties is one of the essential requirements of any civil suit.
But all parties are not necessary for the suit to be adjudicated upon. Therefore,
necessary and non-necessary parties have to be distinguished between. Necessary
Parties are those parties from whom relief is claimed. Non-necessary Parties are those
parties who may be party to the suit, but from whom no relief has been claimed. The
presence of necessary parties is obviously required for the court to adjudicate and
pass an effective and complete decree granting relief to the plaintiff. However, the
same does not hold good for non-necessary parties. In the absence of necessary
parties, the court may dismiss the suit, as it shall not be able to pass an effective
decree. But a suit can never be dismissed due to absence of non-necessary parties.
The underlying logic is that the burden of providing relief should rest upon all the
defendants. It would be unfair if only some of the defendants had to discharge this
burden. Therefore, the plaintiff has to implead all those parties from whom he is
claiming relief to the suit.

The Code of Civil Procedure, the procedural law relating to civil suits can be classified
into two parts, "Body of the Code" and "Rules". The latter deals with non-joinder of
parties. Order 1, Rule 9 lays down the procedure to be followed in cases of non-joinder
of parties. This shall be discussed in greater detail in the course of this article.

Non-joinder can be defined as an omission to join some person as a party to a suit,

whether as plaintiff or as defendant, who ought to have been joined according to the
law. In other words, non-joinder means an omission to join a party to the suit. The
Code does not define non-joinder, but lays down "No suit shall be defeated by reason
of … non-joinder of parties, and the court may in every suit deal with the matter in
controversy so far as regards the rights and interests of the parties actually before it. "
The proviso to this Rule however excludes its applicability to cases of non-joinder of
necessary parties. Necessary Parties are those parties in the absence of whom no
effective decree can be passed by the court. For instance, in a suit filed against a
partnership firm, all partners would be necessary parties. As against this, non- Top
necessary parties are those parties in the absence of whom the court can still
adjudicate in an effective manner
adjudicate in an effective manner.

If a suit is dismissed straightaway for a non-joinder of necessary parties, the plaintiff

will have to file the suit again, resulting in multiplicity of litigation. The Code, through
various legal provisions seeks to prevent multiplicity of litigation. For this reason, the
court may add the necessary parties on its own, or may even direct the plaintiff to do
so. However, since adding necessary parties to the suit is procedural in nature, the
same has to be done at the time of trial, but without prejudice to the plea of limitation
of the parties involved.

In this article, the researcher shall first begin with the meaning of joinder of parties to
a suit. Thereafter, he shall address the question of who are the necessary parties to a
suit. Finally, the legal consequences of non-joinder of necessary parties shall be
analyzed with reference to case laws, so as to appreciate the judicial interpretation of
the relevant legal provisions.

Joinder of Parties

A. Meaning And Essential Requirements of A Civil Suit

Civil Law represents an individuals private right of action for redress. A civil suit (also
referred to as a civil proceeding or simply suit) is a process for recovery of an individual
right or redress of an individual wrong. The essential requirements of any civil suit,
according to the decision of the Bombay High Court in Krishnappa v. Shivappa are
the opposing parties, the subject matter in dispute, the cause of action and the relief
claimed by the plaintiff. For the purposes of the project, we shall be concerned only
with the opposing parties.

The opposing parties quite logically would refer to the plaintiff and the defendant.
Since civil law deals with only those rights that are private in nature, legal action for
enforcing the same can be initiated only by he whose civil rights have been violated.
Thus, there has to be a plaintiff in civil suits. The plaintiff would demand relief from the
person who has violated his civil rights, the defendant. The parties to a suit shall be
either on the side of the plaintiff or the defendant. What has to be considered is to
what extent should parties be joined to a suit. In this connection, the Code provides for
compulsory joinder of all those parties necessary for the court to decide the suit, and
consequently grant relief to the plaintiff.

B. When Can Joinder of Parties Take Place?

Joinder of Parties means joining several parties as plaintiffs or defendants in the same
suit. All or any of those persons can be joined to a suit as plaintiffs or defendants in
Top
whom the right to any relief is alleged to exist, or who is alleged to possess any interest
in the subject-matter of litigation, or in the opinion of the court is a proper or a
 j g p p p
necessary party. The fundamental consideration appears to be the existence of a right
of relief in relation to the party. The opinion of the court shall also be based upon
whether there is a right of relief in relation to the party in question.

In the Code, Order 1 deals with parties to a suit. Inter alia, it provides for joinder of
defendants, and plaintiffs. The plaintiff can implead defendants to a suit. In Mosley v.
General Motors Corp. Ltd., the plaintiff (Nathaniel Mosley) along with 9 other persons
joined in bringing an action individually and as class representatives alleging their
rights under a statute were denied by General Motors, Local 25, United Automobile,
Aerospace and Agriculture Implement Workers of America (Union), simply by reason of
their colour and race. The plaintiffs intended to bring about a joinder of defendants.
On this point, the district court held that there could not be a joinder of defendants
since joint actions would mean a number of issues that would have little relationship
with one another. The essential requirement in this connection is that issues of fact or
law have to be similar. Not all the issues need to be similar, nor do the issues have to
be identical. Relying upon a decided case, the court held that a joinder can take place
only when there is a right of relief out of the same transaction, and issues of fact/law
involved are common to all the plaintiffs. The concerned court may also order separate
trials if it is of the opinion that joint trials will involve delay or prejudice the defendants.
The civil court shall apply its discretion in this respect, and its decision can be reversed
on appeal only if it can be proved that there was an abuse of such discretion. The
interests of both sides have to be ensured. On the one hand, the plaintiff has to be
entitled to speedy relief, thus enabling him to file a single suit against several
defendants. At the same time, the defendants should not be prejudiced in their
representation in the suit, or they shall be denied their right to a fair hearing.

In the present case, the court also discussed the policy and law governing the
operation of Rule 20 of the Federal Rules. The purpose of this rule is to promote trial
convenience, and also expedite final determination of disputes. Single trials are
generally known to reduce delay, cost and inconvenience to all concerned, not just the
parties but also the courts. The US judiciary, as is the case in India too, strongly
encourages joinder of claims, parties and remedies, as evident from the following
words of the US Supreme Court, "Under the Rule the impulse is towards entertaining
the broadest possible scope of action consistent with fairness to the parties." In India,
the legal position relating to joinder of parties can found in Order 1, Rules 1 and 3[16].
According to the aforesaid, the joinder of plaintiffs and defendants requires a right of
relief in respect of the same act or transaction, which has to be alleged to exist. Apart
from this, there have to be common issues of fact or law involved. All those issues do
not have to be common, but even if there is a single common issues, that shall permit
a joinder of parties. Thus, it may be concluded that the legal position relating to joinder
of parties in both Indian and US legal systems is substantially similar. The fundamental
considerations in both systems are the same, and so are the purposes of the aforesaid Top
legal provisions.
At the same time, how far should modern procedure provide for autonomy to plaintiffs
in impleading defendants? Should the plaintiffs have the final word as to the joinder of
defendants? In Watergate Landmark Condominium Unit Owners' Association v. Wiss,
Janey, Elestner Associates, the limits of the plaintiffs to join additional parties were laid
down. The plaintiffs hired a real estate management firm to oversee maintenance of
the units. On receiving complaints from owners about balconies crumbling, the firm
hired an engineering firm (the defendants) to draw specifications for carrying out
repairs, on the basis of which another agency was hired. Not satisfied about the
repairs, the plaintiffs sought relief from the real estate and management firm, but not
against the agency conducting the repairs. In this case, the court held that claims could
not be filed against third parties in the absence of any secondary liability, as per Rule
14 (a). Further, it was held that the statute provides for a right of contribution "only
where the person injured has a right of action against two persons for the same and
indivisible injury." Finally, the plaintiff failed to join the parties since there was no joint
liability.

As far as joinder of plaintiffs is concerned, the important factor is that there should be
a common act or transaction out of which the relief is claimed, and not common
causes of action. So, it is even possible for several plaintiffs to be joined together in a
suit, so long as the aforesaid requirements are satisfied. However, persons may be
jointly interested in a suit, in which case their interests have to be common, and in no
way antagonistic. Moreover, their interest has to lie in the subject matter of the suit,
not in any other question that may be incidental or secondary to the main issue in
question. Similar to joinder of defendants, there has to be a common (not identical)
issue of fact or law involved.

Necessary Parties

A. Who Are The Necessary Parties To A Civil Suit?

A necessary party is a party without impleading whom a claim cannot be legally settled
by court. In other words, in the absence of a necessary party, no effective and
complete decree can be passed by the court. There is no standard for determining
who are the necessary parties to a suit. This shall depend upon the facts and
circumstances of each case. For instance, in a suit filed against a public servant in
relation to his public functions, the government shall have to be impleaded but in a
suit filed against the same person in relation to his not paying maintenance to his
divorced wife, the government shall not be a necessary party.

As already mentioned, there is a distinction between necessary and non-necessary

(proper) parties. In the absence of a necessary party, no order can be effectively
passed by the court. However, a proper party is one in whose absence an effective
Top
order can be passed; whose presence is not needed for a complete and effective
adjudication.
adjudication.

B. Test For Determining The Necessary Parties To A Civil Suit

Although there is no definite test to be applied in this connection, the tests that have
been laid down in Deputy Commissioner of Hardoi v. Rama Krishna, are as follows:
# There has to be a right of relief against such a party in respect of the matters
involved in the suit.
# The court must not be in a position to pass an effective decree in the absence of
such a party.

Generally, a party from whom no relief is sought is not a necessary party. In Pravin v.
State of Maharashtra, the government bought a plot of land under a statute, and
afterwards, sold it to the appellant. The sale was declared invalid by the Supreme
Court. The original owner sought relief. It was held that the party which had purchased
the plot of land from the government was not a necessary party, because no relief was
claimed from it. In Gujarat SRTC v. Saroj, the legal representatives of the deceased
driver of a car which collided with a SRTC bus, claimed compensation from the SRTC. In
the present suit, it was held that the owner of the car and its insurer were not
necessary parties since no relief had been claimed from them. Thus, the nature of
relief claimed is important in deciding who is a necessary party. Necessary parties are
essentially those parties from whom the plaintiff has claimed relief, not those parties
from whom he may claim relief. Proper parties need not be impleaded. Therefore, if
complete and effective relief can be claimed by the plaintiff from some parties, there is
no need to join other parties since other parties are not necessary parties.

In relation to companies, and similar entities that exist independently of their

members, a suit against the entity does not amount to a suit against its members. If
the plaintiff has been granted permission to file a suit against the company, it does not
allow him to do so against the individual directors. The principle of "lifting the
corporate veil" is inapplicable in such cases, because the wrong being complained of is
civil in nature[25]. However, this legal principle shall not apply to partnership firms and
trust, since they do not enjoy a legal existence independent of their members. In
general, if a suit is instituted against a particular identifiable group, all the members of
such a group have to be impleaded whether in personal or in representative capacity.
So a suit filed if filed against a partnership firm has to implead all the partners. Their
absence may lead to dismissal of suit. Similarly, if a suit is filed against a trustee, all the
trustees have to be impleaded, otherwise no decree may be passed.

The government enjoys no immunity in so far as civil suits are concerned. If the
government issues a notification, against which the plaintiff chooses to file a suit, the
government shall also be a necessary party. In suits that are filed against a public
Top
officer, for damages or for any other relief, in respect of an act done by him in official
capacity, the government will also be a necessary party.
capacity, the government will also be a necessary party.

In General Manager, South Central Railway, Secunderabad v. AVR Siddhantti,

there was a non-joinder of parties. The plaintiff claimed relief against the Railways by
impleading it through its representatives. The appellants contended that the
employees who were likely to be affected by the decision had not been impleaded.
Further, it was contended that since they were necessary parties, their non-joinder was
fatal to the petition. However, the Supreme Court turned down this preliminary
objection, holding that the relief was being claimed against the Railways only and it
had been impleaded through its representative. Employees who were likely to be
affected by the decision were at best proper parties. Their non-joinder could not be
said to be fatal to the petition. This supports the proposition that a necessary party is
one against whom relief is claimed. Those who are likely to be affected by the decision
of the court do not automatically become necessary parties. The court may adjudicate
upon their rights and liabilities, but their presence is not needed to pass an order. The
purpose of any civil suit is to grant relief to the plaintiff whose civil rights have been
infringed. Therefore, adjudication upon rights and liabilities of parties should be done
only to that extent. However, anybody whose interest is likely to be directly affected by
the decision of the court is a necessary party. But this means such a person should be
called upon to bear the relief claimed by the plaintiff.

In K Kamaraja Nadar v. Kunju Thevar, the question of who are the necessary parties
to an election petition was decided upon. An election petition can call into question
any election, challenging the fairness of the election, and may be presented by any
candidate or elector. A petitioner may further pray for a declaration that he or any
other candidate has been duly elected. In such a situation, he must implead all
contesting candidates other than the petitioner, and also anyone against whom he has
alleged use of unfair practices. Such contesting candidates will have to be joined as
respondents to such a petition. Any failure to do so will amount to non-joinder of
necessary parties. This defect cannot be cured by way of an amendment of the
petition, since the Election Tribunal does not enjoy the authority to amend the petition
after it has been presented.

In Praveen Bhatia v. Dr. M Ghosh, the plaintiff filed a suit against a doctor due to
whose negligence his wife had died. The doctor was held to be a necessary party (since
relief has been claimed from him). But the insurance company with whom the
insurance has been obtained is neither a necessary nor a proper party, since no relief
has been claimed from it.

Consequences of Non - Joinder of Parties

A. Meaning of Non - Joinder Top

Non-joinder means an omission to join some person as a party to a suit, whether as
plaintiff or as defendant who ought to have been joined according to the law. Non-
joinder of parties refers to a situation in which those parties whose presence is
essential and in whose absence no effective decree can be passed by the court have
not been impleaded. They are those parties who should have been joined under Order
1, Rule 10 (2) of the Code. In contrast, presence of proper parties is needed only for the
court's convenience in deciding the dispute. The court shall in their presence only be
able to decide the dispute completely and effectively.

B. Di erence Between Non - Joinder And Misjoinder

Misjoinder of parties means a joinder of a party who ought not to have been joined
either as a plaintiff or as a defendant. In other words, it refers to impleading an
unnecessary party. It may also refer to a situation in which a plaintiff is impleaded as a
defendant and vice-versa (party wrongfully impleaded). However, Non-joinder refers to
a situation when a party who ought to have been impleaded according to the law is
not impleaded. As opposed to presence of the wrong party, it refers to absence of a
party. In case of non-joinder of necessary parties, the suit may be dismissed, but this is
not so in case of misjoinder.

C. Consequences of Non - Joinder of Necessary Parties

Non-joinder of parties is not fatal to a suit. However, a distinction between non-joinder

of someone who ought to have been joined and someone whose joinder is only
necessary for convenience is necessary. The former are necessary parties, while the
latter are only proper parties. Order 1, Rule 9 of the Code deals with non-joinder of
parties, but is only a procedural provision, which does not affect the substantive rights
and duties of parties.

The absence of necessary parties means those parties from whom relief is being
claimed are not present, due to which the court cannot pass any effective decree. In
such circumstances, the suit can but does not have to be dismissed. If found legally
justifiable, the court should grant the relief being claimed by the plaintiff by passing a
decree between the parties actually before it, so long as that can be done legally and
effectively. The defendant can plead non - joinder of parties by the plaintiff. However,
he shall have to specify who those parties are and what their interest is in the suit. The
defendant has to claim a non-joinder of parties at the earliest, in the written
statement. However, he is also required to specify who are the parties who he wants
should be impleaded, and the rights claimed by them. Should he only give a vague
statement in this respect, it is not sufficient to dismiss the suit on the ground of non-
joinder of parties. In the present suit, the plaintiff claimed a recovery of possession.
The original owner passed away leaving four sons, of whom one son passed away. Top
That son came to be substituted by his son. The sale deed was executed by Gopaljis
sons and his grandson The appellant took the stand that he intended to purchase the
sons and his grandson. The appellant took the stand that he intended to purchase the
entire right, title and interest in the suit property. The defendant contended that in the
absence of the owner the plaintiffs suit is not maintainable and should be dismissed.
The Supreme Court however refused to dismiss the suit on the grounds of non-joinder
of parties since his plea relating to non-joinder was found to be vague. The court also
upheld an important legal principle - in a suit claiming property, until and unless all the
other co-owners are not impleaded, the suit shall not be maintainable. (In
Laxmishankar Hairshankar Bhatt v. Yashram Vasta )

The general principle of law is that the plea of non-joinder should be raised at the
earliest available opportunity. However, an exception is partition suits, in which the
plea of non-joinder of parties can be raised at any point of time. The reason for this, as
laid down in Shanmugham v. Saraswati is that this materially affects the subject -
matter involved in the suit.

The law however only assists the plaintiff on this point. So if he persistently refuses to
implead proper parties, the courts shall act contrary to the and dismiss the suit. In a
civil suit it is the plaintiff who has to claim relief. However, he has to implead the
necessary parties to a suit. Should he refuse to do so even after an objection is raised
in this connection, the suit will be dismissed.

Rules 9 and 10 of Order 1 are essentially complementary in nature. The latter inter alia
deals with the addition of parties to a suit, by which the court can on its own or by an
application by any of the parties order a party to be joined as plaintiff or defendant if it
feels its "presence may be necessary in order to enable the court effectually and
completely to adjudicate upon and settle all the questions involved in the suit. " By
invoking this fairly widely worded provision, the court can order any of the necessary
or even proper parties to be joined. The main advantage herein is that it confers upon
the court to rectify a situation in which the plaintiff has failed to join the necessary
parties, instead of dismissing the suit. Moreover, the addition of parties to a suit can
take place at any point of time. But the defendant should not be likely to be prejudiced
by this. In other words, this should not affect him in preparing for his defense;
otherwise it denies him a fair trial, guaranteed to him under the Constitution. The
plaint shall have to however be amended to this extent, but that is only a procedural
requirement. The court also has the inherent jurisdiction to add or delete parties from
the suit, which it may do at any point of time. Thus, the court may save a suit if due to
a bona fide mistake it is instituted in the name of the wrong plaintiff, or it is not certain
whether it has been instituted in the name of the right plaintiff. However, being a
general provision, it cannot override specific ones. For instance, the Representation of
Peoples' Act enjoins the penalty of dismissal of an election petition for non-joinder of
parties. So the court cannot override this provision by invoking Order 1, Rule 10.

The plea of non-joinder has to be pressed at the earliest opportunity in the trial court.
It may also be taken in the appellate court, but cannot be successfully raised in the
second appeal. The underlying logic is procedural defects in a suit should be checked
at the earliest. To this extent, the plaint may be amended. If the defendant does not
object to non-joinder of parties in the written statement, it will be deemed that he is
not interested in objecting. Essentially procedural in nature, it shall not apply to
determine the substantive rights of parties. Holding that joinder or non-joinder of
parties is too technical, it was held that this shall not operate to deny a person any
benefit under any enactment. In Narendra Singh v. Oriental Fire and General
Insurance Co. Ltd., Delhi, the benefit of Section 39 of the Motor Vehicles Act was
extended to the plaintiff even though the suit suffered from a non-joinder of parties. At
the same time, non-joinder should not be construed too liberally; otherwise the parties Top
shall stand to lose. If a partnership firm against another firm files a suit, all the
partners have to be impleaded as plaintiffs but not their legal representatives For this
partners have to be impleaded as plaintiffs but not their legal representatives. For this
reason, in Brij Kishore Sharma v. Ram Singh, the Supreme Court, reversing the
decision of the trial court, held that the suit is not maintainable. Pending the suit, one
of the parties died and his legal representatives were not brought on record. In the
opinion of the court, the legal representatives should have been brought on record.

D. Compulsory Joinder, and Addition of Parties

Compulsory joinder of parties obviously brings one to the question of whether certain
persons not joined as parties actually have sufficient interests in the suit, to the extent
that they must be joined. Also, if they cannot be joined, will the suit be allowed to
proceed, or will it have to be dismissed. The history of the law governing compulsory
joinder of parties is rather complicated. With reference to the American law on this
point, some of the applicable principles, also recognized in India are:
# All those who are interested in a controversy are necessary parties to a suit involving
that controversy, so that a complete disposition of the dispute may be made.
# Joinder of necessary parties is not necessary when it is impossible, impractical or
involves undue complications.
# A party unless represented by one who is a party is not bound by the decree.

The rule of indispensable party was based on the premise that a court should do
"complete justice or none at all. " Therefore, if a party in the absence of whom a suit
cannot be decided is not impleaded, the suit shall be dismissed. However, there was
an inherent fallacy that the court could only deal with those parties actually before it.
In Shields v. Barrow, the US Supreme Court held that parties to a suit can be classified
into " necessary " and "indispensable ", according to the nature of their rights. The
Federal Rules of 1938 also recognized this legal position. Under Rule 19, possessing
"joint interest " is what distinguished permissive and compulsory joinder. No
guidelines have been provided in this respect, thus showing the requirements of
compulsory joinder have to be decided in the light of the facts and circumstances of
each case. In Pulitzer Polster v. Pulitzer, the US Court of Appeals dealt with the issue of
whether the district court has abused its discretion in dismissing a suit by invoking
Rule 19, instead of allowing it to proceed in the absence of parties. The plaintiff sought
damages from her uncle, because of the alleged improprieties while he was acting as
the sole voting trustee of Wembley Industries Inc. Prior to the suit, her mother and
sister had brought a suit in Louisiana state court, out of the same dispute, wherein the
suit was dismissed for non-joinder of necessary parties. The US Supreme Court held
that the relevant federal rules intend to bring all those having an interest in the subject
of an action together in one forum so that the suit may be disposed off fairly and
completely. The court also referred to a decided case wherein it had been held that
Rule 19 (b) deals with the interests of the plaintiff, defendant, absentees, and public.
The plaintiffs interest would be in relief being available to him in a single suit, while Top
that of the defendant would be in preventing multiplicity of litigation, inconsistent
relief or sole liability for the wrongs that he himself has not committed Rule 19 (a)
 relief, or sole liability for the wrongs that he himself has not committed. Rule 19 (a)
defines those who are needed for the purpose of adjudication of disputes. It is meant
to identify those cases wherein an absent person should be joined if feasible. In other
words, such cases include those in which the existing suit cannot properly achieve its
purpose, or in which there is the likelihood of unfair repercussions to the absent
parties. However, sometimes it is not feasible to join a party needed for adjudication.
In such circumstances, it is for the judge to decide whether in equity or good
conscience the judgment should stand

As has already been noted, addition of necessary parties may be ordered by the court.
Though a necessary party has a right to be included to the suit, that is not so in case of
a proper party. However, even a proper party may apply to the court to be joined. The
court must primarily consider whether the presence of that party would enable the
total adjudication of the suit or not. The discretion of the court is wide in this respect. If
the presence of such a party is essential or highly desirable, in the interests of justice,
the court can order the same. In Raja Ram v. Anant Ram , a suit had been filed for the
dissolution of partnership and accounts in which one partner was the head of a joint
Hindu family business. The son of such a partner was held to be a necessary party who
could be impleaded to the suit. However, the court would not be adjudicating upon his
rights so as to grant relief to the plaintiff.

The question of addition of parties is essentially a judicial discretion that shall have to
be exercised in the light of the facts and circumstances of each case. The court may be
of the opinion that adding a party would be better so as to enable it to effectually and
completely adjudicate upon the controversy. The principle of direct interest shall be
suitably liberalized in such a case. The addition of parties may be justified if at the time
of instituting the suit, he was not impleaded for some reasons. Also, it may be likely
that the party may not have been a necessary or proper party at that point of time, but
subsequently the position has changed. The underlying characteristic shall still be that
his presence shall be helpful in enabling the court to decide the dispute. This was held
in Setabi Devi v. Ramadhani Shaw. The purpose of this provision is to give an
opportunity to all parties to be heard. Thus, those parties from whom no relief has
been claimed may also be added, since they may be affected as a consequence of the
decree.

Consequences of Non - Joinder of Parties That Are Not Necessary

Parties

Non-joinder is not sufficient reason to dismiss the suit if the parties not impleaded are
not necessary parties. The court shall in such a situation first call upon the plaintiff to
chose that he wants to proceed against with the suit. The plaintiff has to decide who
he would like to claim relief from. If he does not implead a particular party, that party
shall not be a bound by the decree passed.

The researcher would like to contend that while a misjoinder can be solved simply by
adding or deleting the names of parties, this cannot be done as far as non-joinder is
concerned. Thus, there is an anomaly since both have the same consequence - the
plaintiff is unable to effectively claim relief from the defendant. In case of a misjoinder,
the suit shall have to be returned for the plaintiff to decide from whom he wants to
claim relief, whereas in cases of non-joinder, the suit shall ordinarily be dismissed if
there is a non-joinder of necessary parties.
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