A party demonstrably affected by an interim order is a proper party entitled to impleadment in writ proceedings.

The Appellant owns a commercial property in Jalandhar for which building plans were approved in 2011

In 2024, a completion certificate was denied due to a front setback discrepancy.

On December 15, 2025, the State of Punjab notified the Punjab Unified Building Rules, 2025 (“2025 Rules”), which reduced setback requirements, potentially making the Appellant’s building compliant

These Rules were challenged in CWP No. 38742 of 2025, where the High Court issued an interim order on December 24, 2025, keeping inconsistent provisions of the 2025 Rules in abeyance

Municipal authorities subsequently relied on this stay to seal the Appellant’s premises and issue a demolition order

The Appellant filed applications for impleadment and clarification of the interim order in CWP No. 38742 of 2025.

The High Court dismissed these on February 26, 2026, holding the Appellant had no lis and was not a necessary party

Concurrently, the Appellant’s independent writ and statutory appeals against the demolition were either dismissed or pending as LPA No. 760 of 2026 and CR No. 2579 of 2026

1. Whether the High Court was justified in holding that the Appellant had no lis in the proceedings and was not a necessary or proper party for impleadment

2. Whether the High Court erred in declining the prayer for clarification/modification of an interim order that was being directly applied to the detriment of the Appellant’s property

3. What procedural course should be adopted regarding the interlinked proceedings consisting of the parent writ petition, the intra-court appeal, and the civil revision

The Court primarily applied the principles of impleadment under Order I Rule 10 of the Code of Civil Procedure, 1908, which serves as a guide for writ proceedings under Article 226 of the Constitution

It relied on the distinction between a "necessary party" (without whom no effective order can be passed) and a "proper party" (whose presence enables complete adjudication) as established in Mumbai International Airport Private Limited v. Regency Convention Centre and Hotels Private Limited (2010) 7 SCC 417

The court further applied the principle that a person directly and demonstrably affected by an interim order cannot be excluded from proceedings where the scope of that order is being interpreted

The Supreme Court observed that the High Court’s interim order dated December 24, 2025, did not remain an abstract challenge but was actively invoked by municipal authorities to deny the Appellant the benefit of the 2025 Rules and to justify demolition

Consequently, the Appellant was not a stranger to the controversy; their property rights were materially affected by the operation of the Court’s own stay order

The Court reasoned that once it is shown that an interim order is being applied to a third party’s detriment, that party becomes a "proper party" whose presence is necessary for a fair adjudication of the order's consequences

Regarding the multiple pending litigations, the Court noted that while the proceedings are interlinked, they arise from distinct causes of action

It held that independent remedies should not be rendered dormant or illusory by indefinitely awaiting the outcome of a broader challenge, as doing so would cause continuing prejudice to the party seeking relief against demolition

The Court directed that the High Court may proceed with the parent writ (CWP No. 38742 of 2025) independently, while LPA No. 760 of 2026 and CR No. 2579 of 2026 should be heard together and disposed of on their own merits

Crucially, the Court ordered the parties to maintain status quo regarding the property until the High Court disposes of the intra-court appeal and the civil revision

All substantive questions regarding the validity of the 2025 Rules and their applicability to the Appellant's building were kept open