P&H: Allows transferee pendente lite to be impleaded as plaintiff in pending injunction suit.

punjab-haryana
⚖️ Order Date: 29 May 2026
Headnotes

Civil Procedure Code, 1908, O.22.R.10, O.1.R.10, S.151 — Impleadment of transferee pendente lite — Where plaintiffs had sold their entire interest in suit property during pendency of suit through registered sale deeds, purchaser had a subsisting interest and ought to have been impleaded as plaintiff no.9 U.O.22.R.10...

Civil Procedure Code, 1908, O.22.R.10 — Assignment or devolution of interest during pendency of suit — In case of assignment, creation or devolution of any interest during pendency of a suit, suit may by leave of Court be continued by or against person to whom such interest...

Civil Procedure Code, 1908, O.22.R.10 — Scope of inquiry at stage of leave — No detailed inquiry at the stage of granting leave is contemplated - Court has only to be prima facie satisfied and question about existence and validity of assignment or devolution can be considered...

Civil Procedure Code, 1908, O.22.R.10 — Impleadment of transferee pendente lite — A transferee pendente lite is bound by final decree that may be passed in suit and may be joined as a party to protect his interests - Where transfer is of entire interest, transferor...

Civil Procedure Code, 1908, O.22.R.10, O.1.R.10, S.151 — Impleadment of transferee pendente lite —  Suit was at the stage of evidence of plaintiffs and transfer had taken place during pendency of suit - In such circumstances, impleadment of purchaser as plaintiff No. 9 was in the interest...

 


Facts of the Case

P&H: Allows transferee pendente lite to be impleaded as plaintiff in pending injunction suit.

High Court has set aside a trial court order and allowed a purchaser of plaintiffs’ entire share in a property dispute to be impleaded as plaintiff No. 9 in a pending suit for permanent injunction.

The case arose from a suit filed by respondents No. 4 to 11 seeking to restrain the defendants from blocking a passage measuring about 20 feet by 304 feet, which allegedly led from a public road to their land. During the pendency of the suit, the plaintiffs sold their entire holding to  Real Estate and Infrastructure through six registered sale deeds.

The purchaser then moved an...

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