Sunday, 29 June 2014

Basic rules for determining whether a party is a necessary party?



 From the above, it is now clear   that two 
tests     are   to   be   satisfied     for   determining   the 
question who is  a necessary party.  Tests  are – (1) 
there must be a right to   some relief against such 
party in   respect of the controversies   involved in 
the   proceedings; (2)   no effective decree can be 

passed in the absence of such party.”

IN THE HIGH COURT OF JUDICATURE AT BOMBAY
 BENCH AT NAGPUR 

WRIT PETITION NO: 5541 /2013 
Shrikrushna   Narayan  Tupkari

v e r s u s

Mahadeo   s/o Bansilal  Dahale

CORAM:   A.B.CHAUDHARI, J.
DATED  :   27th February,  2014 

Citation; 2014(3) ALLMR 811 Bom

Rule. Rule made returnable forthwith, with the consent 
of the rival parties.
By means of  present petition, the  petitioner has put to 
2. 

challenge   the order   dated 19.5.2013 passed by learned District 
Judge­2,   Akola     (below   Exh.   23)   in   Regular   Civil   Appeal   No.
31/2013,   by which the   said Application (Exh.23)   filed by the 
present petitioner,  was  rejected.
3.
In support of the Writ Petition Mr.A.S.Mehadia, learned 
counsel for the petitioner challenged the impugned order on the 
ground   that   the   petitioner   is   a  bona   fide  purchaser   for   value 
without notice to the suit  property  and he came to know  about 
pendency   of   the   Appeal   against   the   judgment   and   decree   for 
specific performance of contract that  was passed by the  learned 
trial Judge in RCS No. 388/2012 and, therefore, in order to save 
his interest, filed   Application (Exh.23)   in the pending Appeal. 
The   lower   Appellate   Court   rejected   the   Application   (Exh.23) 

only on the  ground that the petitioner is  a  subsequent purchaser 
and is a stranger to the litigation and in view of Section 52 of the 
Transfer of  Property Act (henceforth referred to  as “ the T.P
. Act”), 
as per the doctrine of lis pendens,   the  decree is binding on him. 
As such, he cannot be allowed to participate in the proceedings in 

Appeal since he is neither   a necessary party nor   a proper party. 
According   to   Mr.Mehadia,   the   petitioner     was   cheated   by 
respondent no.2  and  he would be losing his hard­earned income 
with   which   he   purchased   the     suit   property,   he   having     no 
knowledge  about the  suit or the decree that  was passed, which is 
ultimately   challenged   before   the   lower   Appellate   Court.   He 
submitted   that   the   petitioner   being   a   person   who   has   been 
deceived,   cannot be denied the entry from the doors of the Court 
in order that the   petitioner can put up his case before the lower 
Appellate Court and  show his bona fides  and the manner in which 
he was deceived  and also  may get some relief  if the Court finds 
accordingly.       But   then,   according   to   him,   closing   the   doors   of 
justice to him would be   doing   severe injustice to him and also 
will   give   rise   of   multifariousness   of   litigation.     He,   therefore, 

prayed for allowing Application  (Exh. 23).
Per contra,   Mr.U.J. Deshpande, learned counsel for the 
4.
respondent   no.1     argued   that   his   client   holds   a     decree   in   his 
favour for specific performance of contract in respect of the  earlier 
contract with the respondent no.2   that   was eventually   passed 

without contest   from the respondent   no.2  and he is entitled to 
take advantage   of the decree passed by the competent court of 
law in his favour.  The petitioner,  according to  Mr.Deshpande, is 
a mere  stranger.      His transaction, if any,  is hit by  doctrine of lis  
pendens  contemplated under Section 52 of the T.P
. Act  He relied 
on the decisions reported in 2013 (2) Civil L.J. 503 (Vidur Impex  
vs.   Tosh   Apartmentrs     &   others);     AIR   2005     SC   2813   (1)  
Kasturi     vs.   Iyyamperumal   and   others;  and   argued   that   it   is 
consistently held that   such a person is not   a necessary party to 
the suit or in the Appeal. He,therefore, prayed for dismissal of the 
Petition. 
5.
Mr. B.N.Mohta, learned counsel appearing on behalf of 
respondent no.2 supported the impugned order.

6.

Upon hearing  the learned counsel for  the rival parties 
and   upon   perusal   of   the   impugned   order,   so   also     the   various 
judgments of the Hon’ble Supreme Court,  I think  it will be proper 
to state  few relevant  facts  in this  case.
The     respondent   no.1­Mahadeo     filed   the   Suit     for 

7.
specific   performance   of   contract     against   the   respondent   no.2 
­Smt. Priyawanda   in respect of the suit property namely,  a house 
at Emerald Colony,  Geetanagar,   Akola  vide Special Civil Suit No. 
170/2010   (new RCS No. 388/2012).   The suit was filed on the 
ground that   the respondent no.2 had entered into an agreement 
of   sale   with   respondent   no.1   on   16.02.2010   for   a   total 
consideration   of Rs. 4,25,000/­ and that the sale deed would be 
completed by 16.05.2010.  The said suit proceeded and ultimately 
a decree came to be passed on 11.2.2013  in faovur of  respondent 
no.1     and against the respondent no.2. It appears that the suit 
was   not   contested   by   respondent     no.2.   The   respondent   no.2 
approached   the   petitioner   and     agreed   to   sell   the   same   suit 
property   to  the  petitioner for    a   total sum  of  Rs.     9,00,000/­ 

with a condition that   the petitioner should clear the outstanding 
loan amount from Vidarbha Premier  Housing Cooperative Society. 
The petitioner agreed   and   accordingly   he cleared all the dues 
and obtained sale  deed  from the  respondent no.2  on 26.2.2013. 
The     Respondent   no.2     preferred     an   Appeal   before   the   lower 

Appellate Court   vide R.C.A. No.31/2013.     In the   said   Appeal, 
the present petitioner filed Application (Exh.23)     for  addition of 
party under Order  1 Rule 10  of the Civil Procedure Code on the 
ground that he  was not aware about the suit  that   was filed and 
decree that  was passed and he  almost paid the double the  price 
than that of  respondent no.1  and  got the sale  deed in his favour, 
while   there was   no sale   deed in favour of the respondent no.1 
though there  was decree passed on 11.02.2013 in his  favour.  The 
petitioner,   therefore,   submitted   that   he   was   deceived     by   the 
respondent     no.2   and   he   being   a  bona   fide  purchaser   for   value 
without any notice, was entitled to be added   as   a party to the 
Appeal so that his  grievance can also be  taken into consideration 
while  deciding the Appeal.

8.

The     lower  Appellate   Court     considered    plethora   of 
judgments   and   eventually     found   that   the   petitioner   was   a 
stranger and in view of the doctrine of   lis pendens,    he  was not 
required to be  added  as a party to the Suit since as per Section 52 
of the T.P
 Act, the  decree would be binding on him. The petitioner 
ig
approached the Court at a very belated stage  i.e. after passing of 
the judgment and decree and the right of the original plaintiff/ 
respondent   no.1 has been confirmed by passing a decree in his 
favour.   According   to   the   Court,   the   petitioner   is     neither     a 
necessary party nor  a proper party.
9.
In my opinion, the above facts will have to be taken 
into consideration to find out whether the petitioner is a necessary 
or property party or not.  In  Ramesh Kundanmal  vs.   Municipal  
Corporation   of   Greater   Bombay   :   (1992)   2   SCC   524    in 
Paragraph 6,   the Hon’ble Supreme Court has observed thus,
“6.......................A necessary party is one without 
whom no order can be  made effectively. A proper 
party is one in whose absence an effective   order 
can be made but  whose presence is necessary for 

a   complete   and   final   decision   on   the   question 
involved in the proceeding. The addition of parties 
is generally not a question of initial jurisdiction of 
the Court but  of  a judicial discretion which has to 
be   exercised     in   view   of     all   the   facts   and 
circumstances of  a particular  case.”

In   Anilkumar  Singh vs. Shivnath Mishra (1995) 3  
SCC 147,     in paragraph 7 the Hon’ble  Supreme Court observed 
thus,
 By  operation of  above  quoted rule  though 
“7.
the Court may  have power to  strike out the name 
of a party improperly joined  or add  a party either 
on   application   or   without   application   of   either 
party, but the condition precedent is that the Court 
must be satisfied that the presence of the party to 
be added, would be necessary in order to enable 
the Court to effectually  and completely  adjudicate 
upon and settle all questions involved in the suit. 
To bring   a person   as party­defendant is not     a 
substantive     right   but   one   of   procedure   and   the 
Court   has   discretion   in   its   proper     exercise.   The 
object   of the rule is   to bring on record and the 
persons who are parties to the dispute relating to 

the   subject­matter   so   that     the   dispute   may   be 
determined     in   their   presence     at   the   same   time 
without any protection, inconvenience and to avoid 
multiplicity of proceedings.”
In  Mumbai   International   Airport   (P)   Ltd.       vs.  

Regency   Convention Centre: (2010) 7 SCC 417,   in paragraph 
15,  the  Hon’ble Supreme Court observed thus, 
“15....................A   ‘proper   party’     is   a   party   who, 
though     not   a   necessary   party,   is   a  person   whose 
presence   would     enable   the   Court   to   completely, 
effectively   and   adequately     adjudicate   upon   all 
matter sin dispute in the suit, though he need not 
be     a   person   in   favour   of    or    against   whom  the 
decree is made.”
It also observed in paragraph 22  as under :­
“   22.......................The   said   sub­rule     is   not   about 
the  right    of   a   non­party   to     be   impleaded     as   a 
party, but  about the judicial discretion of the Court 

to   strike   out   or   add   parties   at   any   stage   of   a 
proceeding. The discretion  under the sub­rule  can 
be exercised either suo motu or on the application of 
the plaintiff or the defendant, or on an application 
of a person who is not a party to the suit.”
ig
The   three Judges’ judgment in the   case of    Kasturi  
vs.   Iyyamperumal,   (2005)   6     SCC   733,      the   Apex   Court   in 
paragraph 7 has observed thus;
“7.
In   our   view,   a     bare   reading     of   this 
provision, namely, second part of Order  1 Rule  10 
sub­rule   (2)   CPC       would   clearly   show   that   the 
necessary parties in  a suit for specific performance 
of a contract for sale are the parties to the contract 
or if they are dead, their legal representatives   as 
also  a  person  who  had purchased  the  contracted 
property from the vendor. In equity as well as   in 
law,   the   contract   constitutes   rights   and   also 
regulates the liabilities of the parties. A purchaser 
is a necessary party as he would be affected if he 
had     purchased     with   or   without   notice   of   the 
contract, but a person who claims adversely  to the 

claim   of     a   vendor   is,   however,   not   a   necessary 
party.   From the above, it is now clear   that two 
tests     are   to   be   satisfied     for   determining   the 
question who is  a necessary party.  Tests  are – (1) 
there must be a right to   some relief against such 
party in   respect of the controversies   involved in 
the   proceedings; (2)   no effective decree can be 

passed in the absence of such party.”
In Amit Kumar   Shaw vs.  Farida Khatoon :(2005)  
11 SCC 403,  two judges  of the  Hon’ble Surpeme Court in para 
16  observed thus,
“16. The   doctrine   of   lis   pendense   applies       only 
where  the   lis  is pending  before     a Court.  Further 
pending the suit,  the transferee   is not entitled  as 
of right to be made a party to the suit, though the 
Court has   a discretion to make him   a party. But 
the     transferee   pendente   lite   can   be   added     as   a 
proper party if his interest in the subject­matter of 
the   suit   is   substantial   and   not   just   peripheral.     A 
transferee   pendente   lite       to   the   extent   he   has 
acquired   interest   from   the   defendant   is     vitally 
interested in the litigation, where the transfer is of 
the   entire   interest   of   the     defendant;   the   latter 

having no   more interest in the property may   not 
properly defend the suit. He may  collude  with the 
plaintiff.   Hence,   though   the   plaintiff   is   under   no 
obligation to make a lis pendens  transferee a party, 
under Order XXII, Rule   10   an alienee   pendente 
lite may be joined   as   party.     As already noticed, 
the Court has discretion in the matter which must 

be   judicially     exercised   and   an   alienee   would 
ordinarily   be joined   as a party to enable him to 
protect his interests.”
Taking upon  the conspectus of the  view  taken by the 
10.
Hon’ble Supreme Court in the earlier judgments, in the   case of 
Vidur Impex  & Traders Pvt.Ltd.  vs.   Tosh  Apartments Pvt.Ltd.  
And others : (2012) 8 SCC 384 finally in paragraph 41, the Apex 
Court  laid down the following principles:
“41.
Though there is   apparent   conflict   in 
the   observations   made   in   some   of   the 
aforementioned   judgments,   the   broad   principles 
which should  govern disposal of an application for 
impleadment  are :

The   court   can,     at   any   stage   of   the 
proceedings, either on an application made by the 
parties   or   otherwise,   direct     impleadment   of   any 
person as party,  who ought to have been joined   as 
plaintiff  or defendant or whose presence before the 
court   is     necessary   for   effective       and   complete 

adjudication  of the issues involved in the suit.
41.2
A     necessary   party   is   the   person   who 
ought to be joined as party to the suit and in whose 
absence   an effective decree   cannot be passed by 
the court.

A   proper   party   is     a   person   whose 
presence   would   enable   the   court   to   completely, 
effectively and properly adjudicate upon all matters 
and   issues,   though   he   may     not   be   a   person   in 
favour  of or against whom a decree is to be made.
If a person is not found to be  a proper 
or   necessary   party,   the   court   does   not   have   the 
jurisdiction to order his impleadment   against the 
wishes  of the plaintiff.

In a   suit   for     specific performance,  
the court can order impleadment   of a purchaser  
whose   conduct   is   above   board,   and   who   files  
application   for   being joined   as   party within  
reasonable time of his acquiring knowledge about  
the pending litigation. (emphasis supplied)
However,     if   the   applicant   is   guilty   of 


contumacious     conduct     or is     beneficiary   of a 
clandestine   transaction or a transaction made   by 
the owner   of the suit property   in violation of the 
restraint   order   passed   by   the   court   or   the 
application is unduly  delayed    then the court will 
be   fully     justified   in   declining   the   prayer   for 
impleadment.”
11.
Upon   perusal     of   paragraph     41   of   the     aforesaid 
judgment   of the Hon’ble Supreme Court, in my  view, there is  no 
straight­jacket formula   in respect of such cases  whether to allow 
or   disallow   a   subsequent   purchaser   on     record   of   the   suit       or 
appeal as necessary  or proper party to the suit.   In the light of the 
dictum   laid down by the Hon’ble Supreme Court in the suit for 

specific performance of  contract  for which  I have  supplied the 
emphasis  above,  and in the light of the  facts of the present  case, 
in my  opinion, the petitioner is a person who was clearly deceived 
by respondent   no.2 by   contracting   with him   merely because 
the   respondent no.2   was getting     double the price     that   was 
ig
agreed     with   the   original   plaintiff   or     respondent   no.1   herein­ 
Mahadeo. The petitioner  prima facie  did not   have     knowledge 
when   the   sale   deed    was     executed   in   his   favour,   either   of  the 
pendency  of the suit in the trial Court or of passing of the decree 
in favour of  respondent no.1 but  was  caught  in a  trap  laid by 
the   respondent   no. 2 who accepted the total consideration and 
executed   sale   deed   in   his   favour   on   26.02.2013.     As   per   the 
doctrine of  lis pendense  under Section 52 of the T.P
. Act the sale 
deed in favour of the petitioner   does not automatically   become 
void  or illegal but the decree passed in the lis may be binding on 
the petitioner.   But then the rights of the person like the petitioner 
who stood deceived,   can  certainly be worked out  by the Court 
ultimately by passing the decree instead of asking such person to 
go  and  to file another suit.     In my opinion,   that  would also 
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save     the   multiplicity     of   litigation   or   an   avoidable     second 
litigation. As a matter of fact, such a person like the petitioner in 
that   event, would be able to     put up his   case for   a  bona fide 
purchaser for value   without  any  notice  or knowledge      and of 
deception practised  on him.    It is not that Section 52 of the T.P

ig
Act closes   the doors   of justice to such a person in the litigation 
merely   because   he   came   to   know     late   about   passing   of   the 
decree,   of   pendency of the suit or the Appeal, as the   case may 
be. In the   backdrop of the   above­referred facts     in the instant 
case   and   in  the  light   of  the  observations made   by  the  Hon’ble 
Supreme Court   as   quoted by me above,   I think   the petitioner 
should   have   been   allowed   by   the   lower   Appellate   Court   to 
participate in the proceedings of Appeal which is pending before it 
instead of  driving him out of the Court.
12.
There is a  serious omission in the relevant legislation 
for the last several years due to which  persons like the petitioner 
have  been  suffering  hardship  and misery  and   high  risks in  the 
property   transactions in the country.     It is     a matter of anxiety 

that   no   corrective   step   has   yet   been   taken   by   the   legislature 
though   the   issue     very   much   concerns   the   people   in   the   entire 
country.    A little care was taken by  Bombay Act No.14/1939 by 
providing  for  Bombay Amendment to Section 52,   but then the 
said amendment of the   requirement by amended provision   has 

not been made applicable to the areas other than only the Greater 
Bombay in the State of Maharashtra. It is, therefore, strange   that 
in the State of Maharashtra itself, the said amendment of   1939 
which is beneficial of the people   at large in the State,   has not 
been made  applicable in the entire State, except  Greater Bombay 
till the next date. It is in the above background,  the Apex Court in 
the   year   2010     while   rendering     decision   in   the     case   of    T.G.  
Ashok Kumar  vs. Govindammal and another  : (2010) 14 SCC  
370,    made a  very significant suggestion to the law­makers  but 
even then no corrective steps have been yet   taken     by either of 
the   Legislature.   It   would   be     appropriate   to   quote   the   relevant 
paragraphs  from the said judgment :

19.
A  related  suggestion to the law­makers:
It is necessary  to refer to  the hardship, 
loss, anxiety and unnecessary  litigation caused  on 

account   of   the   absence   of     a   mechanism     for 
prospective   purchasers   to   verify   whether   a 
property is subject to any pending suit or  a decree 
or   attachment.   At   present,   a   prospective 
purchaser can easily find out   about any  existing 
encumbrance over a propertty either by inspection 
of   the   registration   registers   or   by   securing   a 
ig
certificate     relating   to   encumbrances   (that   is, 
copies of entries in  the registration registers) from 
the jurisdictional   Sub­Registrar  under Section 57 
of the Registration Act, 1908. But  a    prospective 
purchaser   has   no   way   of   ascertaining   whether 
there is any suit  or  proceeding  pending in respect 
of the property, if  the person offering the  property 
for   sale   does   not   disclose   it   or   deliberately 
suppresses   the   information.   As   a   result,       after 
parting with   the consideration (which is many   a 
time the lifetime savings),  the purchaser gets   the 
shock  of his life  when he  comes to know that the 
property purchased by him  is subject to litigation, 
and     that   it   may   drag     on   for   decades     and 
ultimately   deny him title to the property.     The 
pendente lite purchaser will have to wait for the 
litigation to come to an   end or he may have to 
take   over   the   responsibility   of   conducting   the 
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litigation if the transferor   loses   interest after the 
sale.   The purchaser may also face   objections to 
his   being   impleaded   as   a   party   to   the   pending 
litigation on the ground   that being  a lis pendense 
purchaser,  he is not a necessary a party.   All  these 
inconveniences, risks, hardships and misery could 
be avoided and the   property litigations could   be 
ig
reduced    to a considerable extent, if there is some 
satisfactory   and   reliable   method   by   which   a 
prospective purchaser can   ascertain whether any 
suit is pending (or whether  the property is subject 
to   any decree    or attachment) before  he decides 
to purchase the property.
20.
It   is    of  some   interest   that   a  solution 
has   been   found     to   this   problem   in   the   State   of 
Maharashtra by  an appropriate  local amendment 
to Section 52   of the Act, by Bombay Act   14   of 
1939.   Section   52,   as   applicable     in   Maharashtra 
and Gujarat, reads thus ( the amendment is shown 
in Italics):
52.  Transfer   of   property     pending   suit  
relating thereto: (1) During    the pendency 
in any   court having authority     within the 
limits of India excluding  the State of Jammu 
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and   Kashmir     or   established     beyond   such 
limits by the Central Government  of any suit 
or proceeding which is not     collusive     and 
in which any right  to immovable property is 
directly   and     specifically   in   question,  if     a  
notice   of     the   pendency     of   such   suit     or  
proceeding is registered   under Section 18   of  
ig
the   Indian   Registration   Act,   1908,   the  
property     after   the   notice   is     so   registered 
cannot   be   transferred   or   otherwise   dealt 
with by any party to the suit or proceeding 
so as to affect the  rights  of any other party 
thereto    under  any  decree   or  order  which 
may   be   made   therein,   except   under   the 
authority   of the court  and on such terms as 
it may impose.
(2)
Every   notice of pendency   of a suit or  
proceeding referred to in sub­section (1) shall  
contain the following particulars, namely;
(a)
the name  and  address of the owner of  
immovable property or   other person   whose  
right     to   the   immovable   property     is   in  
question;
(b)
the   description   of   the   immovable  
property,the right to  which is in question;
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the   court     in   which   the   suit   or  
proceeding is pending;
(d)
(c)
21
the   nature     and   title     of   the   suit     or  
proceeding; and 
(e)
the date on which the suit or proceeding  
was instituted.”
ig
(emphasis supplied)
21.
We  hope that the Law Commission and 
Parliament considers such     amendment or other 
suitable amendment to cover the existing   void in 
title     verification   or   due   diligence     procedures. 
Provision   can     also   be   made   for     compulsory 
registration of such   notice sin respect of decrees 
and   in   regard   to   attachments     of   immovable 
properties.
22.
We may also   refer   to another related 
area   where   registration   should   be   made 
compulsory   to   reduce   property   litigation.   At 
present in most  of the States, agreements to sell 
are     not compulsorily   registrable as they do not 
involve transfer of any right, title  or interest in an 
immovable   property.   Unscrupulous     property 
owners     enter   into   agreements   of   sale   and   take 
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huge  earnest money  deposits/ advances, and then 
sell the property  to others thereby  plunging   the 
original   agreement­holder   and   the   subsequent 
purchaser   into   litigation.   Registration   of 
agreements   of sale will reduce such litigation. It 
will also  assist in putting  an end to the prevalent 
practice   of   entering   into     agreements   of   sale 
ig
showing     the   real   consideration   and   then 
registering the sale deed for only  a part of the real 
23.
consideration.
If   all     agreements     of   sale     are 
compulsorily   registered, that will go  a  long way 
to discourage   generation and circulation of black 
money   in   real   estate   matters,   as   also 
undervaluation   of   documents   for   purposes   of 
stamp duty.  It  will also discourage   the growth of 
land mafia     and musclemen   who dominate the 
real  estate   scene   in   various  parts   of  the   country. 
Prevention   of     a   malaise,   is   always   better   than 
allowing  a malaise to develop  and then trying to 
cure it.”
CONCLUSION:
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13.
In the above circumstances, the anxiety   expressed by 
the   Apex   Court     as   above,     ought   to   be   taken   care   of     by   the 
Parliament   as   well   as   State   Legislature.   The   State   Legislature 
ought to extend the said amendment  of  Bombay Act No.14/1939 
to the entire State of Maharashtra rather  than   resting it only to 
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Greater   Bombay.   Except   saying   this,   this   Court     cannot     say 
anything more.
14.
Turning back to the  present litigation having  recorded 
the conclusions by me  as above, the following order will have to 
be  passed:­
ORDER
Writ Petition No.5541/2013 is allowed.
ii) The   impugned   order     dated     19.05.2013   (below   Exh.23) 
i) 
passed by learned District Judge­2, Akola  in  R.C.A. No.31/2013 
is set aside.
iii)
The  Application (Exh. 23)  filed by the petitioner is allowed. 
The petitioner be   added   as a party to the Appeal in R.C.A. No. 
31/2013.   The amendment shall be carried out within four weeks. 
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wp.5541.13
24
The Appeal shall be heard thereafter. 
No order as to costs.
v) The Registrar  of this Court   to send copy of this judgment to 
iv) 
the Ministry of   Law & Justice, Shastri Bhawan, New Delhi and 
Chief Secretary, Maharashtra State,  Mantralaya, Mumbai­32,  for 
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information and  necessary action.
JUDGE
sahare
   
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