A lis pendens purchaser is bound by the litigation outcome and is not a necessary party.

The subject property (0.376 Hect. at Village Temri) was originally owned by Respondents No. 2 and 3, who sold it to Sangeeta Agrawal in 1991

Sangeeta subsequently sold the land to Respondent No. 1 (Sanjay Kumar Nachrani) via a registered sale deed in 1997

While Respondent No. 1 was initially mutated in the revenue records, a clerical error later caused the records to reflect Sangeeta’s name instead

Respondent No. 1 applied for correction under Section 115 of the Chhattisgarh Land Revenue Code, 1959.

The SDO allowed this correction on 19.12.2024

This was set aside by the Additional Collector and the Commissioner, but eventually restored by the Board of Revenue on 09.03.2026

During the pendency of the revision before the Board of Revenue, the Petitioner (Dipti Agrawal) purchased the suit property from Respondents No. 2 and 3 via a registered sale deed dated 10.11.2025

The Petitioner filed this writ petition challenging the Board of Revenue's order on the grounds that she was not impleaded or heard despite being the current title holder

1. Whether a lis pendens purchaser is a necessary party to revenue revision proceedings and is entitled to leave to challenge an order passed in her absence.

2. Whether the Petitioner can claim the status of a bonafide purchaser despite the pendency of litigation and an existing civil suit regarding the title of the property.

The Court primarily applied the Doctrine of Lis Pendens under Section 52 of the Transfer of Property Act, 1882, which dictates that property under litigation cannot be transferred so as to affect the rights of any other party under a decree

The Court relied on Rajender Singh Others v. Santa Singh Others [1973 (2) SCC 705] and T.G. Ashok Kumar v. Govindammal Another [2010 (14) SCC 370], establishing that an alienee acquiring property during litigation is bound by the decree even if not impleaded

Section 55 of the Transfer of Property Act regarding the buyer’s duty to verify title

Section 50 of the Chhattisgarh Land Revenue Code, 1959, concerning notice to interested parties in revision.

The Court observed that the Petitioner purchased the property on 10.11.2025, while the revenue revision was actively pending before the Board of Revenue

Under the doctrine of lis pendens, the Court held that the Petitioner "stepped into the shoes" of her sellers (Respondents No. 2 and 3), who were already parties to and actively contesting the proceedings

Consequently, the Petitioner was bound by the outcome of the litigation and could not claim an independent right to be heard as a "necessary party"

Furthermore, the Court noted that Respondents No. 2 and 3 had already filed a civil suit (Civil Suit No. 492-A/2024) for declaration of title, acknowledging their title was "in cloud" at the time of sale to the Petitioner

The Court found the Petitioner failed her statutory duty under Section 55 of the Transfer of Property Act to verify the title and the pending litigation before the purchase

Since the original sellers’ rights were properly adjudicated, no prejudice was caused that necessitated the Petitioner’s independent impleadment

The Court held that a purchaser pendente lite is bound by the final adjudication of the pending litigation and does not have an absolute right to be impleaded if the transferor is already contesting the case

The order of the Board of Revenue dated 09.03.2026 remains undisturbed.