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  • Sect. 91 of the Transfer of Property Act
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  • Sect. 91 of the Transfer of Property Act
Smart Summary

Factual and Procedural Background

Two plaintiffs sued in O.S. No. 6 of 1919 to recover properties that formed endowments attached to a temple. They claimed possession in their capacity as trustees entitled to manage the trust. The Subordinate (Lower) Court found that the first plaintiff had no right to call himself a trustee and that the trust was vested in another person besides the second plaintiff — Papayya alias Subbayya — who had not been made a party to the suit. Despite this, the Lower Court granted decree to the second plaintiff for ejecting the defendant, observing that it would hold the decree for the benefit of all trustees.

The appellant (defendant below) appealed, arguing the suit was bad for non-joinder of Papayya (a person who the Lower Court had found to be a trustee). On appeal, the matter before the Court was whether Papayya should have been a party and, if so, whether the second plaintiff should be permitted to amend his plaint to add Papayya as a defendant or whether the suit should be dismissed for non-joinder. The appeal was adjourned to ascertain Papayya’s willingness to join; Papayya appeared and expressed unwillingness to be made a plaintiff. A petition was also filed by Arunachala Moopanar denying an allegation in the plaint about his father (the 3rd trustee) not having accepted office.

Legal Issues Presented

  1. Whether the suit was incompetent for non‑joinder of Papayya (Subbayya), a person found to be a trustee of the temple endowments.
  2. If non‑joinder was fatal, whether the plaintiff (second plaintiff) should be allowed at the appellate stage to amend the plaint to add the absent trustee as a defendant instead of the suit being dismissed.
  3. Whether procedural provisions (notably Order I Rule 9 CPC and Section 99 CPC as relied on by respondent) permit the suit to proceed on appeal without joining the necessary trustee, or whether substantive rules of trust law require joinder of all trustees.

Arguments of the Parties

Appellant's Arguments

  • The suit was defective and should have been dismissed because Papayya (Subbayya), who was a trustee in whom the trust was vested, was not made a party.
  • Non-joinder of an indispensable party (Papayya) rendered the suit incompetent.

Respondent's (2nd plaintiff / respondent below) Arguments

  • The Court below properly proceeded and could grant relief in the interest of the institution despite non-joinder, because the defendant was a mere trespasser and Papayya had not pressed any claim.
  • On appeal, counsel for the respondent (Mr. Ramachandra Aiyer) relied specifically on Order I Rule 9 CPC and Section 99 CPC to argue that the appeal could proceed without Papayya being on the record as a party.

Other Relevant Factual Positions Noted in the Opinion

  • Papayya appeared by vakil and expressed his unwillingness to be made a plaintiff.
  • A petition by Arunachala Moopanar denied the plaint’s assertion that his father (the third trustee) never accepted office.
  • The Lower Court had given a decree to the second plaintiff and stated it would hold the decree for the benefit of all trustees; the Subordinate Judge had not been moved to add Papayya until after judgment.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Mahabala Bhatta v. Kunhanna Bhatta Shows that an absent party may be added and the suit can proceed after addition; authority relied on in construing joinder questions and Section 99 related arguments. The Court noted the case had been relied upon by respondent’s counsel but observed that it only shows the absent party can be added and that the suit need not be dismissed once the party is added; it does not establish that the suit may proceed without necessary parties.
Kokilasari Dasi v. Mohunt Rudranand Goswami Co‑trustees must act jointly; trustees' interests are indivisible and collective — one trustee cannot act separately. The Court cited it for the proposition that co‑trustees stand on a higher footing and must act together; it noted the case where amendment to convert the nature of the suit was refused and the suit dismissed, illustrating limitations on allowing late amendments.
Kunhan v. Moorthi It is not competent for some trustees, even a majority, to institute a suit without mutual consultation; highlights indivisibility of trustees' powers in certain contexts. Referred to as authority that trustees' interests are joint and indivisible; the Court used it to explain why joinder of trustees is usually required, although the decision there also acknowledged limited circumstances in which a suit might not be dismissed.
Rajendronatht Dutt v. Shaikh Mahomed Lal (Privy Council) When most trustees act from motives personal to themselves (seeking benefit for themselves alone), the proper course is to dismiss the suit for non‑joinder. Used to illustrate that where plaintiffs seek recovery for personal motives, dismissal for non‑joinder is appropriate; contrasts with cases where the institution's interest suggests indulgence.
K. P. Kanna Pishardy v. V. M. Narayanan Somayajipad Shows that where warranted by parties’ conduct, courts may permit amendment and add missing members, returning the suit for trial with the amendment. Cited as an instance where other members were added and the suit remitted for amendment — supporting discretionary relief to add parties in appropriate cases.
Narayanan v. Lakshmanan Co‑trustees were joined as defendants where their title was admitted, and a decree passed in favour of all trustees. Referred to as an example where joinder as defendants was appropriate and resulted in a decree in favour of all trustees; used to demonstrate alternatives to dismissal.
Yakkanath Eacharaunni Valia Kaimal v. Manakkat Vasunni Elaya Kaimal Relied on in relation to Section 99 CPC (contentions about misjoinder/non‑joinder and the power to proceed). Ramesam, J. discussed and disagreed with aspects of this decision’s observations on Section 99, noting that the reasoning about 'mis‑joinder' including 'non‑joinder' was not persuasive in light of later textual changes in procedural rules.

Court's Reasoning and Analysis

The Court began by accepting the Lower Court’s finding that Papayya (Subbayya) was in fact a trustee and therefore ought to have been made a party. The primary legal starting point was the general rule that where several persons have a joint right of action, all must join in suing; if some refuse to come in as plaintiffs they must at least be added as defendants.

The Court then reviewed exceptions to the general rule (listed in the opinion): representative suits under Order I Rule 8 CPC, Section 14 of Act XX of 1863 permitting worshippers, with District Court sanction, to sue singly against trustees for misfeasance or neglect, and certain provisions such as Section 91 of the Transfer of Property Act (redemption suits) and the position of tenants‑in‑common in tort. However, the Court stressed that co‑trustees are treated differently from ordinary joint owners: trustees act collectively and their offices and powers are indivisible — a principle supported by the precedents cited (Kokilasari Dasi, Kunhan v. Moorthi, etc.).

Turning to procedural rules, the Court observed that Order I Rule 9 CPC (no suit to be defeated by misjoinder or non‑joinder of parties) is procedural and gives the Court discretion whether to allow addition of parties at a late stage. The Court recognized that adding parties on appeal may necessitate amending the plaint and recasting issues because new factual questions may arise.

The appeal had been adjourned to ask Papayya whether he would join the prosecution of the respondent’s claim; Papayya appeared and emphatically refused to be a plaintiff. Arunachala Moopanar also filed a petition denying a factual averment in the plaint about his father. Considering the institutional interest of the temple and the procedural posture (the Lower Court had already proceeded without adding Papayya and the point was taken only after judgment), the Court exercised its discretion in favor of correcting the non‑joinder by ordering the addition of the absent trustees as defendants rather than dismissing the suit outright.

Ramesam, J., concurring, emphasized two analytical points: (1) Order I Rule 9 is procedural and cannot alter substantive rules of trust law that require collective action by trustees; and (2) Section 99 CPC should not be interpreted to subsume non‑joinder within "mis‑joinder" simply because earlier decisions treated related language so — he rejected an expansive reading of Section 99 that would permit suits to proceed without indispensable trustees. He then delineated two classes of non‑joinder objections: (a) cases where the absent party is indispensable — the suit must be dismissed unless the party is added; and (b) cases of mere convenience — the party may be added or the suit tried without him. The present appeal fell in the first class (indispensable party), but the Court nevertheless chose to add the absent trustees and remand for retrial in the exercise of discretion, given the institutional interests and circumstances.

Holding and Implications

Core Ruling: The Court allowed the appeal and set aside the decree of the Lower Court. It directed that Papayya (Subbayya) and Arunachala Moopanar be added as defendants and remitted the case to the Court of First Instance to be retried after the newly added defendants file written statements and after the issues are recast as necessary.

Consequential directions and immediate implications included the following (as given in the opinion):

  • The appellant's costs in Appeal No. 128 of 1920 were to be paid by the 1st respondent; the 1st respondent was to bear his own costs in that appeal.
  • The appellant's costs in the Lower Court up to date were to be paid by the 1st respondent and provided for in the revised decree; the memorandum of objections was dismissed without costs.
  • The order disposed also of Appeal No. 168 of 1920; costs of the parties in that appeal were to abide the result and be provided for in the revised decree.
  • The appellants in the two appeals were entitled to a refund of stamp duty on their appeals.

The opinion does not announce the creation of any new legal precedent beyond the application of established principles; it resolves the dispute by ordering addition of indispensable trustees and remanding for retrial while specifying the allocation of costs and incidental relief listed above.

C. K. — Appeal allowed: Case remanded.

    Thina Shanmugha Moopanar v. Mona Chuna Nana Subbayya Moopanar

    Spencer, J. — The two plaintiffs brought this suit (O.S No. 6 of 1919) to recover properties forming the endowments attached to a temple.

    They based their claim for possession upon their rights as trustees in sole management of the trust. The Lower Court found that the 1st plaintiff had no right to call himself a trustee, and although it found that the trust was vested in one other person besides the 2nd plaintiff, namely in Papayya alias Subbayya who was not made a party to the suit, it gave the 2nd plaintiff a decree for ejecting the defendant. It is argued in appeal that the suit was bad for non-joinder of Papayya and should have been dismissed.

    Under the original trust deed (Ex. A) five trustees were appointed and their names were:—1. Ramalinga Moopanar 2. Nallamuthu Moopanar 3. Veerabhagu Moopanar 4. Chokka-linga Moopanar 5. Subbayya alias Pappayya Moopanar and it was provided that on the death of, any trustee, his eldest male son was to carry on the trust provided that he was willing and competent, or failing him, a competent and willing member of the same family might be appointed by the surviving trustees, or failing such a person, then any unobjectionable person from the same community.

    Of the above 5 trustees, No. 5 dropped out, Nos. 1, 2 and 4 died and the plaintiff alleged in his plaint that No. 3 never accepted office and that his place was vacant. The 2nd plaintiff is the son of No. 2 and the 1st plaintiff claimed to be a trustee as nephew of No. 4, who died issuless, but there was not found to be any record of 1st plailntiff's appointment and the Subordinate Judge consequently refused to make a decree in his favour. No. 1 left a son Arumuga Moopanar who by will appointed the defendant Shanmuga Moopanar, manager of the trust properties. Arumuga Moopanar left a minor son Subbayya alias Pappayya Moopanar whose guardian defendant was and who has since attained majority. It is owing to the non-joinder of this grandson of Ramalinga Moopanar that the suit is argued to be incompetent. The Subordinate Judge conceded that the failure to add this person at least as a defendant was a point to be considered, but he got over the difficulty by saying that Pappayya had not cared to come forward to press his claims and that as the defendant was a mere trespasser in the eye of the law, it was for the interest of the institution that the suit should not be dismissed. Accordingly he pronounced judgment in favour of the 2nd plaintiff alone, observing that he would hold the decree for the benefit of all the trustees.

    There is no question to my mind that Pappayya alias Subbayya ought to have been made a party to this suit. The only question is whether the 2nd plaintiff should be allowed at this stage to amend his plaint and to bring Pappayya on the record as a defendant if he will not join him as a plaintiff or whether the suit should be dismissed. It is not now contended that Pappayya is not a trustee, the lower Court's finding that he was never really removed from office, being allowed to go unchallenged in appeal.

    The general rule is that if several persons have a joint right of action all must join in suing. If any of them will not come in as plaintiff, they must be added as defendants.

    O. 1, R. 8, Civil Procedure Code which provides for representative suits, and Sect. 14 of Act XX of 1863 which provides for worshippers, who have got the sanction of the District Court, singly instituting suits against trustees or managers of religious institutions for misfeasance or neglect of duty from exceptions to this general rule.

    Other exceptions are that under Sect. 91 of the Transfer of Property Act any person interested or having a charge over property may bring a suit for redemption of a mortgage and that a tenant-in-common may sue a wrong-doer upon a tort without joining other injured persons (See Mahabala Bhatta v. Kunhanna Bhatta(1).) But co-trustees stand upon a higher footing even than joint owners and joint contractees as regards indivisibility of interest. All form as if it were one collective trustee and they must exercise the powers of their office in their joint capacity and they cannot act separately (Vide Kokilasari Dasi v. Mohunt Rudranand Goswami(2)). As their interests are joint and indivisible, it was pointed out in Kunhan v. Moorthi(3) that it is not competent to some of the trustees or even the majority to institute a suit without mutual consultation and after the majority have signified their will. As that was a suit for redemption it was finally held that the Court was not bound to dismiss it on account of the plaintiff's failure to consult his co-trustees or to make them co-plaintiffs. In Rajendronatht Dutt v. Shaikh Mahomed Lal(4) where 3 out of 4 joint shebaits omitted to join the 4th shebait in their suit to recover alienated property, the Privy Council thought that the proper course was to dismiss the suit, the reason for so doing being that in the opinion of their Lordships those plaintiffs were acting from motives personal to themselves and sought to recover the property for their own benefit alone. In Kokilasari Dasi v. Mohunt Rudranand Goswami it would have been necessary to amend the plaint so as to convert a suit for ejectment and mesne profits inconsistent with redemption into a suit for redemption and the learned judges refused to give leave to the plaintiff to do that and dismissed the suit. In K. P. Kanna Pishardy v. V. M. Narayanan Somayajipad the other members were added and the suit was returned to the Court of First Instance for the amendment of the plaint as such an indulgence appeared to be warranted by the previous conduct of the parties. In Narayanan v. Lakshmanan the co-trustees were joined as defendants as their title was admitted by the plaintiffs at the trial before a decree was passed in favour of all the trustees. In the case before us no petition to add Pappayya was brought to the notice of the Subordinate Judge, till after he had pronounced judgment.

    It seems to me, that apart from the provision in O. 1, R. 9 that no suit shall be defeated by reason of the misjoinder or nonjoinder of parties; which is a rule of procedure, it is a matter for the Court's discretion whether it will allow parties to be added at a late stage, as in appeal when to do so will necessitate an amendment of the plaint and owing to the character of the suit being charged, a recasting of the issues for the determination of the new questions of fact that must arise out of the amendment. Now this appeal having been adjourned to enable the respondent to assertain if Pappayya is willing to join in the prosecution of respondent's claim, Pappayya has appeared by vakil before us and expressed his unwillingness to be made a plaintiff. We have also a petition from one Arunachala Moopanar who says he is the son of Veerabhagu Moopanar the 3rd trustee and denies the assertion in the plaint that his father did not accept office.

    Although it is open to us to dismiss the suit, we have the interests of the institution to consider, and therefore I think that the proper course and the course we should take in the proper exercise of our discretion in these circumstances is to set aside the Lower Court's decree, to direct that Pappayya and Arunachala Moopanar be added as defendants and to send the case back to the Court of First Instance to be retried after receiving the written statements of the newly added defendants and after recasting the issues in such a manner as may be necessary. The appellant's costs in this appeal (Appeal No. 128 of 1920) will be paid by the 1st respondent and the 1st respondent will bear his own costs in the appeal. The appellant's costs in the Lower Court up to date will be paid by the 1st respondent and will be provided for in the revised decree. The memorandum of objections is dismissed without costs.

    This disposes also of Appeal 168 of 1920. The costs of the appellant and 1st and 2nd respondents in this appeal will abide, follow the result and be provided for in the revised decree.

    Appellants in the two appeals are entitled to the refund of stamp duty on their appeals.

    Ramesam, J.—I concur; but I wish to add a few words with reference to a contention of Mr. Ramachandra Aiyer the learned vakil for the respondent. He argued that whatever may be the law as to the joinder of trustees the appeal can now proceed without Pappayya and he relied on (1) O. 1, R. 9 and (2) Sect. 99 of the Civil Procedure Code.

    1. So far as O. 1, R. 9 is concerned, 1 think, it enacts a rule of procedure and it cannot effect rules of substantive law, (such as, for example, the rule of Hindu Law, that all the members of a joint family must be parties to a suit for the partition and the rule of the Law of Trusts that all the trustees must act together). It means that, however much it may be convenient or desirable to add parties, the suit need not be dismissed, if it is possible to deal with the matter in controversy so far as regards the rights and interests of the parties actually before it. It cannot effect any rule of substantitive law that the suit cannot proceed without other parties. The observations in Mahabala Bhatta v. Kunhanna Bhatta are also relied on. They only show that the absent party can be added and the suit can proceed after such addition. In this sense, it is true that the suit need not be dismissed, but it does not follow from them that the suit can proceed without the necessary paties.

    2. As to Sect. 99 Civil Procedure Code the case in Yakkanath Eacharaunni Valia Kaimal v. Manakkat Vasunni Elaya Kaimal is relied on. With all deference to the learned Judges, lam unable to agree with the observations on this section in that case. White, C.J, says “It is contended that Sect. 99 speaks only of misjoinder of parties or causes of action. But it has been held by this Court in Mahabala Bhatta v. Kunhanna Bhatta for the purposes of construing the section to which the present Sect. 99 corresponds that the word misjoinder includes non-joinder”. Now the section of the old Code corresponding to Sect. 99 of the present Code is Sect. 578 which was never referred to or considered in Mahabala Bhatta v. Kunhanna Bhatta. In that case it was said that the word ‘mis-joinder’ in Sect. 31 (of the old Code) included ‘non-joinder’ and to arrive at this conclusion, resort was had to O. 16, R. 13 of the Supreme Court Rules (in its earlier form) and the decisions thereon, a method of reasoning which is now necessary, seeing that the word ‘non-joinder’ is now added in O. 1, R. 9, (corresponding to Sect. 31 of the old Code). Not only does it not follow that the word ‘mis-joinder’ in Sect. 99 should include ‘non-joinder’ but it is clear to me that it should not, seeing that the legislature added the word ‘non-joinder’ to ‘mis-joinder’ in O. 1, R. 9 but omitted to do so in Sect. 99. The language of Krishnaswami Iyer, J., “Therefore Sect. 99 of the present Code of Civil Procedure would seem to be sufficient to dispose of that objection” is very indefinite.

    It seems to me that objections as to non-joinder, if taken at the earliest opportunity (O. 1, R. 13) fall under two classes.

    1. If it is absolutely necessary to have the absent party, he ought to be added unless the plaintiff refuses to add him when the suit should be dismissed. If the trial Court erroneously proceeds with the suit, without following either of these courses, the objection can be repeated in appeal when again, it may be disposed of only in the above said two ways. The present appeal falls under this heading.

    2. If it is not a case of imperative necessity but only a matter of convenience or expedience either the absent party may be added or the suit may be tried without him (O. 1, R. 9). In such a case the objection if repeated in appeal may be dealt with similarly.

    I agree with the order proposed by my learned brother.

    C. K.Appeal allowed: Case remanded.

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    Comments

    Thina Shanmugha Moopanar v. Mona Chuna Nana Subbayya Moopanar
    (Dec 7, 1921)