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  By Abhishek Jat, Advocate Background The Supreme Court, in the matter of  M/S J N Real Estate v. Shailendra Pradhan & Ors.  (Civil Appeal Nos. 5405-5406 of 2025), addressed the question of whether a subsequent purchaser of property should be added as a party to a suit for specific performance, even though such a purchaser may not be strictly necessary for the suit’s outcome. Factual Matrix The dispute revolved around agricultural land originally owned by Indramohan Pradhan. Conflicting claims arose due to two separate wills and multiple agreements to sell, resulting in three parties asserting title over the same property: The appellant (original defendant no. 8), claiming ownership through a registered sale deed executed by a beneficiary under one will. The original plaintiff, who had entered into an agreement to purchase the property from the testator’s sons, beneficiaries under another will. The original defendant no. 4, w...

By Abhishek Jat, Advocate In a significant judgment delivered in Civil Appeal No. 5297 of 2025, the Supreme Court of India has clarified the legal framework concerning the addition of parties to arbitral proceedings under the Arbitration and Conciliation Act, 1996 (ACA). The decision addresses whether the service of a notice invoking arbitration under Section 21 and the inclusion of a party in a Section 11 application are indispensable prerequisites for an arbitral tribunal to assume jurisdiction over that party. Factual Matrix The dispute originated from a Limited Liability Partnership (LLP) agreement between Adavya Projects Pvt. Ltd. and M/s Vishal Structurals Pvt. Ltd., executed for the purpose of undertaking oil and gas sector projects. While only the appellant and respondent no. 1 were signatories to the LLP agreement, the agreement itself designated respondent no. 3 as the Chief Executive Officer of the LLP (respondent no. 2), and provided a broad arbitration clause encompa...