Udit Narain Singh Malpaharia Vs Addl Member, Board of Revenue, Bihar, AIR 1963 SC 786,

Hon'ble Supreme Court of India observed as under, " To answer the question raised it would be convenient at the outset to ascertain who are necessary or proper parties in a proceeding. The law on the subject is well settled: it is enough if we state the principle. 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.”