UDIT NARAIN SINGH MALPAHARIA vs ADDITIONAL MEMBER, BOARD OF REVENUE, BIHAR

The Supreme Court held that under Article 226 of the Constitution of India, a necessary party is one without whom no effective order can be made, while a proper party is one whose presence is necessary for a complete decision. The Court ruled that a writ of certiorari can only be issued against judicial or quasi-judicial acts, emphasizing that such bodies must provide a hearing to all parties affected by their decisions. The Court upheld the High Court's dismissal of the writ petition due to the absence of necessary parties, Phudan Manjhi and Bhagwan Rajak, in the proceedings.