### PLAIN IDENTIFICATION OF IMMOVABLE PROPERTY VIA HOLDING OR PLOT NUMBERS IS MANDATORY FOR EFFECTIVE ADJUDICATION OF SUITS.

The petitioner (plaintiff) filed Title Suit No. 242 of 2017 seeking a permanent injunction regarding property described in Schedules 1 and 2 of the plaint

The petitioner claimed ownership through sale deeds from 1959 and a subsequent family arrangement in 1977

During the proceedings, the respondent (intervenor) filed a petition under Order I Rule 10 CPC to be impleaded, claiming the suit involved "Holding No. 30" in which he had an interest

The petitioner subsequently amended the plaint to delete the reference to "Holding No. 30"

Despite this deletion, the Trial Court allowed the intervention via order dated 13.05.2019

The petitioner challenged this order, arguing the property was no longer identifiable as Holding No. 30 and the intervenor had no stake in the remaining suit property

1. Whether the impleadment of an intervenor is necessary or proper when the subject property lacks specific identification (holding or plot numbers) in the plaint.

2. Whether the Trial Court can adjudicate a title suit or intervention petition when the immovable property is not distinctly identifiable as per statutory requirements.

Order VII Rule 3 of the Code of Civil Procedure (CPC), which mandates that where the subject matter of a suit is immovable property, the plaint must contain a description sufficient to identify it, such as boundaries or numbers in a record of settlement or survey

Order I Rule 10 CPC regarding the joinder of necessary and proper parties, emphasizing that impleadment is contingent upon the party having a direct interest in the specific subject matter of the litigation

The High Court observed that after the petitioner deleted "Holding No. 30" from the plaint via amendment, the suit property became vague, identified only by Ward and Circle numbers

The Court reasoned that mere dimensions and general boundaries are insufficient for legal identification of immovable property

The Court noted that the Trial Court failed to specify the basis for its conclusion that the intervenor still held an interest in the suit property after the specific holding number was removed

The Court determined that without a specific holding or plot number, it is impossible to establish if a cause of action exists or if an intervenor is a necessary party

Consequently, the Trial Court erred by allowing intervention before ensuring the property was distinctly identified

The Court held that the Trial Court must first ensure the identification of the suit property by requiring the plaintiff to provide a specific holding or plot number via affidavit or pleading

The Trial Court was directed to pass a fresh order on the intervention petition only after the property is clearly identified

The application was disposed of with these directions