PATANGRAO KADAM vs PRITHVIRAJ SAYAJIRAO YADAV DESHMUKH — C.A. No. 1789/1998

Case Summary: Patangrao Kadam v. Prithviraj Sayajirao Yadav Deshmukh Decision: The Supreme Court dismissed all appeals and upheld the High Court's dismissal of the election petition for non-compliance with Section 82(b) of the Representation of People Act, 1951. Key Reasoning: The Court held that Sampatrao Chavan, who was a validly nominated candidate but withdrew before polling, remained a "candidate" under Section 79(b) even after withdrawal. Since the election petition alleged corrupt practices against him and sought a further declaration that the petitioner be declared elected, Chavan was a necessary party under Section 82(b) and should have been impleaded as a respondent. The Court rejected arguments that his subsequent role as the returned candidate's election agent eliminated this requirement. Section 82 is mandatory and non-compliance requires dismissal under Section 86(1), overriding procedural amendment powers. This case analysis is maintained by casestatus.in based on publicly available court records.