Amit Kumar Shaw & Anr vs Farida Khatoon & Anr

The Supreme Court addressed the applicability of Order 1 Rule 10 and Order XXII Rule 10 of the Code of Civil Procedure, 1908, alongside Section 52 of the Transfer of Property Act, 1882, in determining the rights of subsequent transferees to substitute parties in ongoing litigation. The Court held that the High Court erred in dismissing the appellants' application for substitution, emphasizing that the presence of the appellants was necessary to resolve the appeal, particularly given their status as bona fide purchasers without knowledge of the pending litigation. Consequently, the Supreme Court allowed the appeals and directed the High Court to permit the substitution of the appellants as parties in the case.