Seenivasan vs Peter Jebaraj & Anr

The Supreme Court upheld the Madras High Court's decision regarding the application of Order I Rule 10(4) and Section 52 of the Transfer of Property Act, 1882, in a dispute over property title. The Court ruled that the addition of Saraswathi Ammal as a defendant did not retroactively affect the validity of her prior sales to Anna Pushpam Ammal and Lalitha Ammal, thereby affirming that the plaintiffs acquired absolute title. The Court clarified that the principle of lis pendens did not apply, as Saraswathi Ammal had conveyed her title before the ex parte decree was passed.