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Non-joinder of Parties in Civil Suits

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Written By : Ashwini Chawla - 2nd Year, National University of Juridical Sciences, Kolkata

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Introduction 
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-necessary parties are those parties in the absence of whom the court can still 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 individual’s 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 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 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 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 order can be passed; whose presence is not needed for a complete and effective 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 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.

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 
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. Difference 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. That son came to be substituted by his son. The sale deed was executed by Gopalji’s 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 plaintiff’s 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 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 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 plaintiff’s interest would be in relief being available to him in a single suit, while 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)  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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Authored by  Ashwini Chawla and can be reached at : ashwinichawla@legalserviceindia.com

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