Introduction
The Civil Procedure Code, 1908 (CPC), serves as the cornerstone of procedural law governing civil litigation in India. Among its intricate provisions, Order 1, Rule 10 and Order XXII, Rule 4 occupy positions of paramount importance in determining the composition of parties in civil suits and addressing the complexities arising from the death of parties during litigation. These provisions operate within the broader framework of the doctrine of dominus litus, which establishes the plaintiff as the master of the suit while balancing this principle with the court’s inherent power to ensure comprehensive adjudication.
The Latin phrase dominus litis, or master of the suit/plaint, is reference to the person who derives the benefit of a favourable judgment and is liable for the effects of an adverse judgment, including expenses. This foundational principle undergirds the entire structure of civil litigation, determining how parties are joined, substituted, or removed from proceedings.
The intersection of these provisions has been the subject of extensive judicial scrutiny, particularly in cases where defendants die during the pendency of litigation. The recent decision of the Jammu and Kashmir High Court in Hakim Din v. Akbar Noor & Ors [1] has provided crucial clarification on the relationship between these provisions, establishing that where Order XXII, Rule 4 applies, the general provisions of Order 1, Rule 10(2) are excluded based on the principle that “general words do not derogate special provisions.”
The Doctrine of Dominus Litus: Foundation and Scope
Historical Development and Legal Framework
The Plaintiff is the one to come up with the litigation having been vested, by law, the right to choose the persons against whom he wishes to litigate, the prerogative to put a valuation to the reliefs claimed by him, to choose the remedy, and the a right to choose the Court or forum in case more than one court has jurisdiction to try the suit/plaint in accordance to the law.
The doctrine of dominus litus represents a fundamental tenet of adversarial litigation systems, recognizing the primacy of the plaintiff’s interests while establishing necessary limitations to ensure justice. This doctrine finds its expression in various provisions of the CPC, particularly in the context of party joinder and case management.
Core Principles and Applications
The doctrine encompasses several key elements that define the plaintiff’s control over litigation:
Party Selection and Strategic Litigation: The Plaintiff, as the dominus litis, is vested with the right to choose the remedy and the forum, if more than one remedy or forum is available, and the opposite party cannot claim that the matter be tried in a specific forum convenient to him. This principle ensures that plaintiffs maintain strategic control over their litigation while preventing defendants from dictating procedural choices.
Valuation and Relief Determination: The doctrine grants plaintiffs discretionary authority to determine the valuation of their claims, particularly in cases involving declaratory relief or specific performance where market valuation may be challenging to establish. However, this discretion is not absolute and remains subject to judicial oversight to prevent arbitrary or capricious determinations.
Limitations and Judicial Oversight: However, the same is subject to the riders of the Order I Rule 10(2) of the Code of Civil Procedure, 1908, which provides for the impleadment of necessary or proper parties. The courts maintain supervisory jurisdiction to ensure that the plaintiff’s exercise of dominus litus rights does not prejudice the interests of justice or result in incomplete adjudication.
Exceptions and Special Circumstances
The doctrine’s application is not uniform across all types of litigation. In a partition suit, the strict application of the principle of Dominus Litus is not applicable because both the plaintiff and defendants are sharers. Similarly, in representative suits, class actions, and certain statutory proceedings, the traditional application of the doctrine may be modified to accommodate the broader public or group interests involved.
Order 1, Rule 10 of the Civil Procedure Code: Addition and Substitution of Parties
Statutory Framework and Legislative Intent
Order 1, Rule 10 of the CPC represents one of the most significant procedural provisions governing party composition in civil litigation. The rule empowers courts to add, substitute, or strike out parties at any stage of proceedings to ensure complete and effective adjudication of disputes.
Sub-rule (1): Wrong Plaintiff Provision: The first sub-rule addresses situations where a suit has been instituted in the name of the wrong person as plaintiff or where doubt exists regarding the propriety of the plaintiff’s designation. This provision ensures that technical defects in party identification do not defeat otherwise meritorious claims.
Sub-rule (2): Addition and Substitution Power: The Court may at any stage of the proceedings, either upon or without the application of either party, and on such terms as may appear to the Court to be just, order that the name of any party improperly joined, whether as plaintiff or defendant, be struck out, and that the name of any person who ought to have been joined, whether as plaintiff or defendant, or whose presence before the Court may be necessary in order to enable the Court effectually and completely to adjudicate upon and settle all the questions involved in the suit, be added.
Judicial Discretion and Standards for Application
The exercise of power under Order 1, Rule 10(2) involves careful judicial consideration of multiple factors:
Necessary Parties: necessary parties are those persons in whose absence no decree can be passed by the court or those persons against whom there is a right to some relief in respect of the controversy involved in the proceedings. The absence of necessary parties renders any decree incomplete and potentially ineffective.
Proper Parties: proper parties are those whose presence before the court would be necessary in order to enable the court effectually and completely to adjudicate upon and settle all the questions involved in the suit although no relief in the suit was claimed against such person. The distinction between necessary and proper parties is crucial for determining the mandatory nature of party joinder.
Judicial Discretion Framework: In exercising its judicial discretion under Order 1 Rule 10(2) of the Code, the court will of course act according to reason and fair play and not according to whims and caprice. Courts must balance competing interests while ensuring that procedural decisions advance rather than impede justice.
Landmark Supreme Court Guidelines
The Supreme Court’s decision in Mumbai International Airport Pvt. Ltd. vs. Regency Convention Centre and Hotels Pvt. Ltd. & Ors [2] established comprehensive guidelines for the application of Order 1, Rule 10(2):
Test for Necessary Parties: The court emphasized that a person can be joined as a party to the suit if his presence is necessary for a complete and effective adjudication of the issues involved. This test focuses on the functional necessity of party participation rather than mere convenience or potential interest.
Specific Performance Context: In suits for specific performance, the Court clarified that the following persons are to be considered as necessary parties: (i) the parties to the contract which is sought to be enforced or their legal representatives; (ii) a transferee of the property which is the subject matter of the contract.
Limitations on Third-Party Claims: a person who claims a title adverse to that of the defendant-vendor will not be a necessary party. This principle prevents parties with competing claims from automatically gaining standing in contractual disputes between original parties.
Contemporary Applications and Evolving Standards
Modern judicial interpretation has refined the application of Order 1, Rule 10(2) to address complex commercial and constitutional litigation:
Commercial Disputes: In commercial transactions involving multiple stakeholders, courts have adopted a pragmatic approach to party joinder, considering factors such as privity of contract, financial interest, and practical necessity for comprehensive resolution.
Constitutional and Public Law Cases: In constitutional matters and public interest litigation, the traditional doctrine of dominus litus may be relaxed to accommodate broader public interests and ensure comprehensive adjudication of constitutional questions.
Electronic Commerce and Digital Transactions: The emergence of digital commerce has created new challenges for party identification and joinder, requiring courts to adapt traditional principles to contemporary commercial realities.
Order XXII, Rule 4 of the Civil Procedure Code: Death of Defendants
Statutory Provisions and Procedural Framework
Order XXII, Rule 4 addresses the specific situation arising from the death of defendants during the pendency of civil litigation. This provision ensures continuity of proceedings while protecting the interests of legal representatives and maintaining the integrity of judicial process.
Core Provisions of Rule 4: Where one of two or more defendants dies and the right to sue does not survive against the surviving defendant or defendants alone, or a sole defendant or sole surviving defendant dies and the right to sue survives, the Court, on an application made in that behalf, shall cause the legal representative of the deceased defendant to be made a party and shall proceed with the suit.
Conditions for Application: The invocation of Order XXII, Rule 4 requires satisfaction of specific conditions:
- Death of Defendant: Actual death of a defendant during the pendency of proceedings
- Survival of Right to Sue: The cause of action must continue to exist against the deceased defendant’s estate
- Non-survival Against Remaining Defendants: Where multiple defendants exist, the right to sue must not survive against the remaining defendants alone
Abatement Consequences: Where within the time limited by law no application is made under sub-rule (1), the suit shall abate as against the deceased defendant. This provision creates a time-sensitive obligation for plaintiffs to seek substitution of legal representatives.
Procedural Requirements and Compliance Standards
The application of Order XXII, Rule 4 involves strict adherence to procedural requirements:
Application Requirements: Applications for substitution must be comprehensive, including identification of legal representatives, evidence of death, and demonstration of the survival of the cause of action. The application must be supported by appropriate affidavits and documentary evidence.
Notice and Hearing Procedures: Courts must provide adequate notice to proposed legal representatives and afford them opportunity to be heard before making substitution orders. This ensures due process and protects the interests of deceased defendants’ estates.
Time Limitations and Condonation: Where the plaintiff was ignorant of the death of a defendant, and could not, for that reason, make an application for the substitution of the legal representative of the defendant under this rule within the period specified in the Limitation Act, 1963 and the suit has, in consequence, abated, and the plaintiff applies after the expiry of the period specified therefor in the Limitation Act, 1963, for setting aside the abatement and also for the admission of that application under section 5 of that Act on the ground that he had, by reason of such ignorance, sufficient cause for not making the application within the period specified in the said Act, the Court shall, in considering the application under the said section 5, have due regard to the fact of such ignorance, if proved.
Legal Representatives and Capacity Issues
The determination of legal representatives involves complex questions of succession law and capacity:
Identification of Legal Representatives: Courts must apply relevant personal law to determine proper legal representatives, considering factors such as intestate succession, wills, and legal capacity of heirs.
Multiple Legal Representatives: Where multiple legal representatives exist, courts must ensure comprehensive representation while avoiding unnecessary multiplication of parties that could complicate proceedings.
Capacity and Authority: Legal representatives must possess legal capacity to represent the deceased’s interests, and courts may require evidence of such capacity through succession certificates or probate proceedings.
Judicial Interpretation and Landmark Cases
Supreme Court Jurisprudence on Party Joinder
The Supreme Court has developed extensive jurisprudence interpreting the interaction between various provisions governing party composition:
Mumbai International Airport Case Analysis: The landmark decision in Mumbai International Airport Pvt. Ltd. vs. Regency Convention Centre and Hotels Pvt. Ltd. & Ors [2] clarified the distinction between necessary and proper parties while emphasizing the court’s discretionary power to ensure complete adjudication.
Balancing Dominus Litus and Judicial Oversight: Consequently, a person who is not a party has no right to be impleaded against the wishes of the plaintiff. But this general rule is subject to the provisions of Order I Rule 10(2) of Code of Civil Procedure, which provides for impleadment of proper or necessary parties.
Specific Performance Context: In the context of specific performance suits, courts have established clear guidelines for determining party necessity, focusing on contractual relationships and property interests rather than speculative or remote claims.
High Court Interpretations and Regional Variations
Different High Courts have contributed to the evolving interpretation of these provisions:
Delhi High Court Approach: Dominus litis is the person to whom a suit belongs and is master of a suit and is having real interest in the decision of a case. The plaintiff being dominus litis cannot be compelled to fight against a person against whom he does not claim any relief.
Practical Application Guidelines: A third party is entitled to be impleaded as necessary party if that party is likely to suffer any legal injury due to outcome of the suit. The doctrine of dominus litis should not be over stretched in impleading the parties.
Balancing Test Development: Courts have developed sophisticated balancing tests to reconcile the plaintiff’s dominus litus rights with the need for comprehensive adjudication and protection of third-party interests.
Contemporary Judicial Trends
Recent judicial decisions reflect evolving approaches to party composition:
Commercial Litigation Adaptations: Courts have adapted traditional principles to address complex commercial arrangements involving multiple stakeholders, joint ventures, and corporate structures.
Constitutional and Administrative Law Contexts: In constitutional and administrative law cases, courts have shown greater willingness to add parties sua sponte to ensure comprehensive adjudication of public law issues.
Alternative Dispute Resolution Integration: The integration of ADR mechanisms has influenced party composition decisions, with courts considering the impact of party addition on the effectiveness of alternative resolution methods.
Case Study: Hakim Din v. Akbar Noor & Ors
Background and Factual Matrix
The decision of the Jammu and Kashmir High Court in Hakim Din v. Akbar Noor & Ors [1] provides a definitive analysis of the relationship between Order 1, Rule 10(2) and Order XXII, Rule 4 of the CPC. The case arose from a suit for declaration and possession filed against three defendants, including one who died during the pendency of proceedings.
Factual Circumstances: The petitioner had filed a suit for declaration and possession against three defendants, including Mohd. Rafiq as defendant No. 1. During the pendency of the suit, Rafiq died, prompting the petitioner to seek inclusion of his legal heirs based on Muslim law of inheritance.
Procedural History: The trial court initially dismissed the petitioner’s application for substitution, holding that the suit had abated against the deceased defendant under Order XXII, Rule 4(3). The defendants opposed the application citing delay in filing.
High Court Intervention: The High Court set aside the trial court’s order, providing crucial clarification on the interaction between the two provisions.
Legal Analysis and Court’s Reasoning
The High Court’s analysis focused on several key legal principles:
Distinction Between Provisions: Differentiating the ambit and scope of Order-1 R-10 (2) and Order-XXII R-4 CPC, the Jammu and Kashmir High Court ruled that while Order-1 R-10 (2) enables the Court to add, substitute or strike down a person impleaded as party to the suit, Order-XXII R-4 on the other hand requires the plaintiff to bring legal heirs/representatives of a deceased defendant on record.
Exclusion Principle: Therefore, where a case is covered by Order-XXII R-4, the provisions of Order-1 R-10 (2) stand excluded on the well known principle “general words do not derogate special provisions”.
Advocate’s Duty: The court emphasized the obligation of advocates to inform the court about the death of parties, recognizing this as a fundamental duty in maintaining the integrity of judicial proceedings.
Implications for Legal Practice
The decision establishes important precedential value for several aspects of civil litigation:
Procedural Clarity: The judgment provides clear guidance on which provision should be applied when defendants die during litigation, eliminating confusion between general and specific provisions.
Legal Representative Substitution: The decision clarifies the mandatory nature of legal representative substitution in appropriate cases and the consequences of non-compliance.
Professional Responsibility: The emphasis on advocate’s duties highlights the importance of professional responsibility in maintaining accurate party records and court information.
Broader Jurisprudential Impact
The case contributes to broader jurisprudential development in several ways:
Interpretive Methodology: The application of the “general words do not derogate special provisions” principle demonstrates sophisticated statutory interpretation techniques.
Procedural Efficiency: The decision promotes procedural efficiency by providing clear guidelines for practitioners and courts in similar situations.
Access to Justice: By clarifying substitution procedures, the decision enhances access to justice for legal representatives of deceased parties.
Procedural Requirements and Practical Applications
Application Procedures Under Order 1, Rule 10(2)
The practical application of Order 1, Rule 10(2) requires careful attention to procedural requirements:
Application Format and Content: Applications must clearly identify the proposed party, specify whether they seek addition as necessary or proper parties, and provide factual and legal justification for the request. The application should address the impact of the proposed addition on existing parties and the overall conduct of the suit.
Supporting Documentation: Comprehensive documentation must accompany applications, including relevant contracts, deeds, corporate records, or other evidence establishing the proposed party’s interest in the subject matter.
Notice Requirements: Adequate notice must be served on all existing parties, allowing them opportunity to oppose the application and present counter-arguments regarding the necessity or propriety of the proposed addition.
Court’s Suo Motu Powers: Courts possess inherent authority to add parties without formal application where necessary for complete adjudication. This power must be exercised judiciously, with due regard for party rights and procedural fairness.
Order XXII, Rule 4 Implementation Framework
The implementation of Order XXII, Rule 4 involves specific procedural steps:
Death Verification Procedures: Courts require authentic evidence of death, typically in the form of death certificates or other official documentation. The timing of death relative to procedural milestones may affect available remedies.
Legal Representative Identification: Proper identification of legal representatives requires application of relevant personal law, consideration of succession rights, and verification of capacity to represent the deceased’s interests.
Abatement Prevention Measures: Plaintiffs must act diligently to prevent abatement by timely filing substitution applications. Courts may consider factors such as knowledge of death, accessibility of information, and reasonable diligence in determining whether delay is excusable.
Cost and Compensation Considerations: Where within the time limited by law no application is made under sub-rule (1), the suit shall abate so far as the deceased plaintiff is concerned, and, on the application of the defendant, the Court may award to him the costs which he may have incurred in defending the suit, to be recovered from the estate of the deceased plaintiff.
Practical Guidelines for Legal Practitioners
Legal practitioners must navigate complex procedural requirements while advancing their clients’ interests:
Case Assessment and Strategy: Early case assessment should identify all potentially necessary and proper parties, considering both immediate litigation needs and potential future complications arising from incomplete party composition.
Client Communication and Consent: The doctrine of dominus litus requires careful client consultation regarding party composition decisions, ensuring that clients understand the implications of including or excluding particular parties.
Monitoring and Compliance: Ongoing monitoring of party status, including health and legal capacity considerations, helps prevent procedural complications and ensures timely compliance with substitution requirements.
Documentation and Record-Keeping: Comprehensive documentation of party composition decisions, including rationale for inclusion or exclusion of potential parties, provides important protection against future challenges and appeals.
Comparative Analysis: Order 1, Rule 10(2) vis-à-vis Order XXII, Rule 4
Scope and Application Differences
The relationship between Order 1, Rule 10(2) and Order XXII, Rule 4 reveals important distinctions in scope and application:
General vs. Specific Provisions: Order 1, Rule 10(2) represents a general provision governing party composition throughout litigation, while Order XXII, Rule 4 addresses the specific circumstance of defendant death. The principle that specific provisions supersede general ones governs their interaction.
Discretionary vs. Mandatory Application: Order 1, Rule 10(2) vests courts with broad discretionary authority to add or remove parties based on necessity and propriety considerations. In contrast, Order XXII, Rule 4 creates more structured obligations triggered by specific factual circumstances.
Timing and Procedural Triggers: Order 1, Rule 10(2) may be invoked at any stage of proceedings based on evolving case circumstances or newly discovered party interests. Order XXII, Rule 4 is specifically triggered by the death of parties and operates within defined temporal limitations.
Interaction Principles and Conflict Resolution
When both provisions potentially apply, courts must employ established interpretive principles:
Lex Specialis Derogat Legi Generali: where a case is covered by Order-XXII R-4, the provisions of Order-1 R-10 (2) stand excluded on the well known principle “general words do not derogate special provisions”. This principle ensures that specific statutory schemes receive priority over general provisions.
Purposive Interpretation: Courts consider the underlying purposes of each provision, recognizing that Order XXII, Rule 4 specifically addresses succession and continuity issues while Order 1, Rule 10(2) focuses on comprehensive adjudication requirements.
Procedural Harmony: Interpretive approaches seek to maintain procedural harmony while avoiding conflicts that could undermine the effectiveness of either provision.
Practical Implications for Litigation Strategy
The relationship between these provisions affects litigation strategy in several ways:
Party Composition Planning: Strategic party composition must consider both immediate litigation needs and potential complications arising from party death or incapacity during extended proceedings.
Risk Assessment and Mitigation: Practitioners must assess risks associated with party death and develop contingency plans for legal representative substitution without compromising litigation strategy.
Procedural Compliance Coordination: Compliance with both provisions requires coordination of different procedural requirements and timing considerations.
Contemporary Developments and Future Perspectives
Technological Impact on Party Identification
Contemporary developments in technology and commerce create new challenges for traditional party composition principles:
Digital Identity and Virtual Entities: The emergence of digital platforms, virtual entities, and blockchain-based organizations challenges traditional concepts of legal personality and party identification.
Cross-Border Litigation Complexities: Increasing international commercial activity creates complex questions regarding party joinder across jurisdictions and the application of domestic procedural rules to international disputes.
Electronic Service and Notification: Digital communication technologies affect notice requirements and party communication obligations, potentially streamlining substitution procedures while creating new verification challenges.
Legislative Reform Considerations
Several areas present opportunities for legislative reform and clarification:
Procedural Streamlining: Contemporary commercial practice suggests potential benefits from streamlined procedures for party addition and substitution, particularly in complex commercial disputes involving multiple stakeholders.
Alternative Dispute Resolution Integration: The growing importance of ADR mechanisms may require reconsideration of traditional party composition rules to accommodate collaborative resolution approaches.
Digital Age Adaptations: Legislative adaptation may be necessary to address digital commerce, virtual entities, and electronic communication realities in party composition procedures.
Judicial Innovation and Adaptive Interpretation
Courts continue to develop innovative approaches to traditional procedural challenges:
Case Management Integration: Modern case management practices integrate party composition decisions with broader case scheduling and resource allocation considerations.
Proportionality Principles: Courts increasingly consider proportionality factors in party addition decisions, balancing comprehensive adjudication needs against litigation efficiency and cost considerations.
Public Interest Considerations: In matters involving public interest or constitutional questions, courts show increased willingness to adapt traditional party composition rules to ensure adequate representation of affected interests.
Conclusion
The intersection of Order 1, Rule 10(2) and Order XXII, Rule 4 of the Civil Procedure Code represents a sophisticated framework for managing party composition in civil litigation while addressing the practical challenges arising from party death during proceedings. The doctrine of dominus litus provides the foundational principle recognizing plaintiff autonomy in litigation management, while judicial oversight ensures comprehensive and fair adjudication.
The Jammu and Kashmir High Court’s decision in Hakim Din v. Akbar Noor & Ors [1] provides crucial clarification on the relationship between these provisions, establishing that specific provisions governing party death supersede general party addition rules. This interpretive approach promotes procedural clarity while maintaining the integrity of both statutory schemes.
Contemporary legal practice requires sophisticated understanding of these provisions and their interaction. Legal practitioners must navigate the balance between plaintiff autonomy under the dominus litus doctrine and the court’s authority to ensure complete adjudication through appropriate party composition. The procedural requirements for both provisions demand careful attention to timing, documentation, and compliance obligations.
The evolving nature of commercial relationships, technological advancement, and international business practices continues to challenge traditional approaches to party composition. Courts and practitioners must remain adaptable while maintaining fidelity to established procedural principles and the underlying goals of comprehensive and fair dispute resolution.
Future developments in this area will likely focus on streamlining procedures for complex commercial disputes, integrating alternative dispute resolution mechanisms, and adapting traditional principles to contemporary technological and commercial realities. The fundamental tension between plaintiff autonomy and comprehensive adjudication will continue to require careful judicial balancing and sophisticated procedural management.
The successful application of these provisions requires not only technical legal knowledge but also strategic thinking about litigation management, client objectives, and procedural efficiency. As civil litigation continues to evolve, these provisions will remain central to ensuring that courts can effectively and completely resolve disputes while respecting party rights and promoting access to justice.
References
[1] Hakim Din v. Akbar Noor & Ors, 2023 LiveLaw (JKL) 149, Jammu and Kashmir High Court. Available at: https://www.livelaw.in/high-court/jammu-kashmir/jammu-kashmir-ladakh-high-court-monthly-digest-june-2023-231730
[2] Mumbai International Airport Pvt. Ltd. vs. Regency Convention Centre and Hotels Pvt. Ltd. & Ors, (2010) 7 SCC 417, Supreme Court of India. Available at: https://www.latestlaws.com/latest-caselaw/2010/july/2010-latest-caselaw-441-sc/
[3] The Code of Civil Procedure, 1908, Order 1, Rule 10. Available at: https://www.indiacode.nic.in/bitstream/123456789/2191/1/A1908-05.pdf
[4] The Code of Civil Procedure, 1908, Order XXII, Rule 4. Available at: https://www.writinglaw.com/order-22-rule-4-cpc/
[5] S.S. Rana & Co., “Dominus Litis Doctrine – India,” Legal Analysis (2023). Available at: https://ssrana.in/articles/dominus-litis-doctrine-india/
[6] The Law Advice, “Order 1 Rule 10 of the Civil Procedure Code (CPC),” Legal Commentary. Available at: https://www.thelawadvice.com/articles/order-1-rule-10-of-the-civil-procedure-code-cpc
[7] LiveLaw, “Delhi High Court Order 1 Rule 10 CPC | Plaintiff Being ‘Dominus Litis’,” Case Commentary (2022). Available at: https://www.livelaw.in/news-updates/delhi-high-court-order-1-rule-10-cpc-impleadment-plaintiff-domunis-litis-204046
[9] Supreme Court of India, “Plaintiff Is ‘Dominus Litis’; High Court Cannot Direct Impleadment,” Legal News (2021). Available at: https://www.livelaw.in/top-stories/plaintiff-is-dominus-litis-high-court-cannot-direct-impleadment-of-additional-defendant-in-suit-supreme-court-187879
[10] Drishti Judiciary, “Doctrine of Dominus Litus,” Legal Resource. Available at: https://www.drishtijudiciary.com/doctrines/code-of-civil-procedure-doct/doctrine-of-dominus-litus
[11] Law Bhoomi, “Doctrine of Dominus Litus,” Legal Commentary (2025). Available at: https://lawbhoomi.com/doctrine-of-dominus-litus/
[12] Lexology, “Plaintiff is the Dominus Litis- India,” Legal Analysis (2023). Available at: https://www.lexology.com/library/detail.aspx?g=6a6f7dd6-dc7d-4cdd-88a2-8da4de6307b4
[13] APS Law, “Role of the Plaintiff as Dominus Litis in India,” Legal Resource. Available at: https://apslaw.co.in/role-of-the-plaintiff-as-dominus-litis-in-india/
[14] TaxGuru, “All about Order 1 Rule 10 of Code of Civil Procedure, 1908,” Legal Analysis (2020). Available at: https://taxguru.in/corporate-law/order-1-rule-10-code-
Authorized by : Vishal Davda
