This document contains the Supreme Court of India's judgement in Civil Appeal No. 6370 of 2022, between Sudhamayee Pattnaik and Others vs Bibhu Prasad Sahoo and Others. It addresses the application of Order 1 Rule 10 of the Code of Civil Procedure, 1908, regarding the impleading of subsequent purchasers as defendants against the original plaintiffs' wishes. The judgement clarifies that plaintiffs are the 'dominus litis' and cannot be forced to include new defendants unless the court deems it essential for proper adjudication. It also considers the implications of a counter-claim filed by the defendants. This judgement is particularly useful for legal practitioners and parties involved in property disputes where subsequent purchasers are a factor.