Doctrine of dominus litis yields to impleadment of interested parties to prevent multiplicity of litigation.

The petitioner (plaintiff) filed a civil suit (Civil Suit No. 01-A/2025) seeking a declaration of title and permanent injunction regarding suit land Khasra No. 2936/1-A/1

The plaintiff claimed possession of the land for over 36 years based on an exchange deed from 1988

During the proceedings, the intervenors (Respondents 5-7) filed an application under Order 1 Rule 10 of the Code of Civil Procedure (CPC), asserting they were in actual possession of the suit land and were necessary parties to protect their interests

On 18.02.2026, the Civil Judge Junior Division, Bilaigarh, allowed the application, directing the plaintiff to implead the intervenors

The petitioner challenged this order under Article 227 of the Constitution of India, contending that as the dominus litis, he cannot be compelled to sue strangers who failed to produce documentary evidence of title

1. Whether the trial court acted within its jurisdiction under Order 1 Rule 10 of the CPC by allowing the impleadment of intervenors who claim possession over the suit land

The court applied the provisions of Order 1 Rule 10 of the Code of Civil Procedure, 1908, which empowers the court to add any person as a party whose presence is necessary to enable the court to effectually and completely adjudicate upon and settle all questions involved in the suit

It also considered the doctrine of dominus litis, which recognizes the plaintiff as the master of the suit, while balancing it against the judicial policy of avoiding multiplicity of litigation and inconsistent decrees

The High Court observed that the core of the plaintiff's suit is a claim for declaration and permanent injunction based on possession

Since the intervenors similarly claimed to be in actual possession of the same suit land, the court found a prima facie interest in their favor

The Court reasoned that although a plaintiff is generally the dominus litis, this rule is not absolute; interested parties must be impleaded to prevent the passing of "controversial decrees" and to curb the "multiplicity of litigation"

The Court further noted that impleadment is beneficial for the plaintiff as it allows for a conclusive determination of the dispute against all claimants in a single instance

The veracity of the intervenors' claims regarding possession is a matter of evidence to be tested during the trial, not at the stage of impleadment

The impleadment was necessary for a complete adjudication of the dispute regarding the suit land

Consequently, the High Court dismissed the writ petition, upholding the trial court's direction to implead the intervenors as defendants