(M) Criminal P.C. (1973), S.223 - Non-joinder of necessary parties - Case of medical negligence against doctors - Patient treated by 16 doctors but only three principal doctors prosecuted - Notices against rest of them withdrawn - Held it cannot by itself be considered as relevant factor for dismissal of appeals.
MALAY KUMAR GANGULY VS. DR. SUKUMAR MUKHERJEE & ORS.
2009-ALL SCR-2039 (Paras 154)