In a suit for the cancellation of a registered sale deed, the vendees are considered necessary parties to the proceedings as their presence is essential for the effective adjudication of the validity of the documents in question.

Headnote:(A) Code of Civil Procedure, 1908 - Order 1 Rule 10 - Impleadment of parties - Necessary vs. Proper parties - Suit for cancellation of sale deeds - Vendees/alienees of suit properties are necessary parties to a suit for cancellation of sale deeds executed in their favour as their presence is required for effective adjudication of the relief sought (Paras 10, 14, 15).

(B) Appellate Review - Court's power to uphold a correct conclusion of the trial court despite erroneous reasoning - Appellate/revisional court need not interfere with a final order if the destination is correct, even if the reasoning is flawed (Paras 18, 19).

Facts of the case:
The petitioner herein was proposed as Defendant No. 22 in an original suit. The plaintiff filed an interlocutory application seeking to implead several additional defendants (Proposed Defendants 15 to 26), including a partnership firm and various individuals who purchased portions of the suit property during the pendency of the suit. The trial court allowed the impleadment, noting the parties were 'proper' parties, despite finding they were not 'necessary' parties.

Findings of Court:
The High Court held that the vendees of the disputed sale deeds are not merely proper, but necessary parties to the suit because the prayer for cancellation of the sale deeds directly impacts their legal title. The court further clarified that the scope of the proceedings against these newly impleaded parties must be limited to the allowed claims (i.e., property ownership and document cancellation) and specifically excluded any claims regarding the dissolution of partnership or rendition of accounts, which had been previously disallowed in related revision petitions.

Issues: (1) Whether the impleadment of the proposed defendants was legally justified. (2) Whether the proposed defendants are necessary or proper parties for adjudication of the remaining claims.

Ratio Decidendi: In a suit for cancellation of a registered sale deed, the vendee is a necessary party because an effective decree of cancellation cannot be passed in their absence, as it would directly affect their rights under the impugned document.

Result: Civil Revision Petition dismissed with modifications/clarifications to the trial court's order.

Table of Content
1. procedural background and facts leading to the application for impleading additional defendants. (Para 1 , 2 , 3 , 4 , 5)
2. principles governing order 1 rule 10 cpc regarding the impleadment of necessary and proper parties. (Para 6 , 7 , 8 , 9 , 10 , 11)
3. determination that purchasers of suit property are necessary parties to cancellation suits. (Para 12 , 13 , 14 , 15 , 16)
4. appellate discretion to confirm trial court's conclusion despite flawed reasoning regarding necessary versus proper parties. (Para 17 , 18 , 19 , 20 , 21 , 22)

O R D E R:

1. This Civil Revision Petition is filed under Article 227 of the Constitution by Petitioner - Proposed Defendant No. 22 in O.S. No. 147 of 2019, assailing the Order dated 01.11.2025 passed by the learned Principal Senior Civil Judge, Mancherial in I.A. No. 163 of 2024, allowed the petition filed by Respondent No.1/Plaintiff under Order 1 Rule 10 of the Code of Civil Procedure, 1908 (hereinafter referred to as 'CPC"), and permitted impleadment of Proposed Defendants 15 to 26 in the suit.

2. This Court notes, at the outset, that the present Revision is connected with Civil Revision Petition No. 4349 of 2025, which assails the Order of the same date passed by the same trial Court in I.A. No.161 of 2024 (amendment of plaint), and Civil Revision Petition No.4355 of 2025, which assails the Order of the same date in I.A. No.162 of 2024 (filing of rejoinder). All three interlocutory applications were filed by Respondent No. 1 - Plaintiff simultaneously and the impugned orders in all three were passed on 01.11.2025. This Court, by separate orders in Civil Revision Petitions No. 4349 and 4355 of 2025, partly allowed the revisions. In Civil Revision Petition No. 4349 of 2025, this Court permitted factual and supplementary amendments to the plaint (including cancellation of eleven additional sale documents executed by Defendant No.1 in favour of his family members and associates after the filing of the suit, and the arraying of the partnership firm as Defendant No.15) while disallowing the amendments seeking introduction of reliefs of dissolution of partnership and rendition of accounts on the ground that such reliefs constitute an entirely new cause of action barred by limitation under Article 5 of the Limitation Act, 1963. In Civil Revision Petition No. 4355 of 2025, this Court permitted filing of a rejoinder subject to condition that it shall not contain any pleas pertaining to dissolution and rendition of accounts that have been disallowed in Civil Revision Petition No. 4349 of 2025.

3. The essential facts giving rise to the present Revision are: Respondent No.1 - Plaintiff instituted the suit seeking declaration of his 1/4th share in the partnership properties, cancellation of certain sale documents executed by Defendant No.1, and consequential injunction. The suit was filed against Defendants 1 to 14. When the suit stood posted for hearing on framing of issues, Respondent No. 1 - Plaintiff simultaneously filed three interlocutory applications, of which I.A. No. 163 of 2024 was filed under Order I Rule 10 CPC seeking to implead Proposed Defendants 15 to 26. The proposed parties included the partnership firm M/s Mathrusri Infra (as Proposed Defendant No.15), three associates of Defendant No.1 (Damodar Lal, Jangam Ramakrishna, and Banda Sampath Reddy as Proposed Defendants 16 to 18), and purchasers/alienees of suit properties (Proposed Defendants 19 to 26), who are stated to be family members and friends of Defendant No.1 to whom he had transferred portions of the suit properties through registered sale deeds during the pendency of the suit.

4. The case of Respondent No.1 - Plaintiff in the impleadment petition was that during pendency of the suit, it came to his knowledge that Defendant No.1 transferred portions of suit schedule properties to the Proposed Defendants 15 to 26 through various registered sale deeds; the said alienees were, in fact, family members and fri

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IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABADNagesh Bheemapaka, JPeddi Karthik – AppellantVersusMoluguri Venkateswarlu – RespondentCIVIL REVISION PETITION No. 4372 OF 2025

In a suit for the cancellation of a registered sale deed, the vendees are considered necessary parties to the proceedings as their presence is essential for the effective adjudication of the validity of the documents in question.

Cases Referred (2)

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Nagesh Bheemapaka, J
Peddi Karthik – Appellant
Versus
Moluguri Venkateswarlu – Respondent
CIVIL REVISION PETITION No. 4372 OF 2025