Mahen Susantha Madugalle vs Chula Swarna Madugalle and Land Reform Commission – SC APPEAL 77/2018-2023

In the case between Mahen Susantha Madugalle and Chula Swarna Madugalle, the Supreme Court addressed whether the Land Reform Commission (L.R.C.) should be joined as a necessary party in a dispute concerning the vindication of paddy land ownership derived through several transfers and deeds. The sequence of events involved the plaintiff’s action to assert title against the defendant, the District Court’s refusal to add the L.R.C. as a party, and the subsequent reversal by the High Court, which was in turn appealed to the Supreme Court. It was held that the L.R.C. need not be added as its involvement would not assist in resolving the core dispute, given that title could be adjudicated solely between the plaintiff and defendant and that the defense of jus tertii did not justify duplication of