CUSTODIAN OF BRANCHES OF BANCO NATIONALULTRAMARINO. vs NALINI BAI NAIQUE

The Supreme Court held that the trial court correctly allowed the substitution application under Order XXII Rule 4 of the Civil Procedure Code, as the widow of the deceased defendant was a legal representative despite her Meeira rights under the Portuguese Law of Inheritance. The Court clarified that a 'legal representative' includes any person who represents the estate of a deceased, not limited to legal heirs. The suit was allowed to proceed as the widow was brought on record within time, and the subsequent impleadment of other heirs did not invalidate the proceedings.