Introduction
The determination of who constitutes a “necessary party” is central to the integrity of adjudicatory proceedings under the Real Estate (Regulation and Development) Act, 2016 (“RERA”). In Soumya Ranjan Jena Vs. Priyata Lipsa and Ors.1, the Odisha Real Estate Appellate Tribunal (“OREAT”) was called upon to examine whether an individual, allegedly connected to a project but not a party to the underlying transaction, could be impleaded in proceedings before the Regulatory Authority. The ruling provides important clarity on the limits of impleadment under Section 31 of RERA and reinforces the principle that liability must be grounded in statutory roles rather than speculative association.