Parties whose rights are directly affected by interim orders in writ proceedings cannot be excluded from participating, establishing the standard for necessary versus proper parties.

JUDGMENT :

VIKRAM NATH, J.

1. Leave granted.

2. The present appeals arise from the judgment and order dated 26.02.2026 passed by the High Court of Punjab and Haryana at Chandigarh¹[High Court] in C.M. No. 2967-CWP-2026 and C.M. No. 2968-CWP-2026 in CWP No. 38742 of 2025, whereby the High Court dismissed the applications filed by the Appellant seeking impleadment in the writ proceedings as well as clarification / modification of the interim order dated 24.12.2025 passed in the said writ petition.

3. The facts giving rise to the present appeals are as follows:

3.1. The Appellant is the owner of property bearing No. B-XIII294, Police Lines Road, Jalandhar. Change of land use from residential to commercial was granted in respect of the said property on 09.10.2006. Thereafter, on 28.04.2011, the Municipal Corporation, Jalandhar approved the building plan for construction of a hotel on the said property. On 31.07.2024, the Appellant applied for issuance of a completion certificate. During that process, a discrepancy relating to the front setback was pointed out. According to the Appellant, the discrepancy arose because the plot on site was trapezium shaped, whereas the sanctioned plan depicted it as rectangular.

3.2. On 15.12.2025, the State of Punjab notified the Punjab Unified Building Rules, 2025²[2025 Rules]. According to the Appellant, under the 2025 Rules the minimum front setback requirement for commercial buildings stood reduced to 10 per cent, and the building of the Appellant, which is stated to maintain a front setback of 15.37 per cent, became compliant with the said regime. The 2025 Rules were thereafter challenged before the High Court in CWP No. 38742 of 2025. By interim order dated 24.12.2025, the High Court directed that those provisions of the notification dated 15.12.2025 which were inconsistent with the earlier Rules and Regulations be kept in abeyance. The High Court further directed that violations which were qualified as violations under the previous Rules and Regulations be not regularized.

3.3. According to the Appellant, the interim order dated 24.12.2025 thereafter came to be relied upon by the municipal authorities while proceeding against its building. On 05.02.2026, the premises on the said property were sealed. On 06.02.2026, a demolition order was issued by the Municipal Corporation, Jalandhar. The Appellant challenged the said action by filing CWP No. 4023 of 2026 before the High Court. By order dated 10.02.2026, the High Court declined to entertain the writ petition and relegated the Appellant to the statutory remedy available under Section 269 of the Punjab Municipal Corporation Act, 1976³[1976 Act]. The Appellant then carried the matter in LPA No. 415 of 2026. By order dated 12.02.2026, the Division Bench disposed of the appeal while relegating the Appellant to the statutory remedy before the competent appellate forum and granted limited protection against precipitative action till 16.02.2026 or till the filing of the appropriate plea, whichever was earlier.

3.4. On 12.02.2026, the Appellant submitted a representation t