#Order XXII CPC

The Bombay High Court has ruled that legal heirs of deceased writ petitioners may be substituted even after a 17-year delay, provided they demonstrate sufficient cause and no prejudice to respondents. This reinforces that constitutional remedies under Article 226 are not extinguished by mere lapse of time, safeguarding the rights of successors in public law litigation.

The Supreme Court has ruled that legal heirs of a deceased doctor cannot be held liable for personal injury damages in consumer complaints, as such claims abate upon death under Section 306 of the Indian Succession Act, 1925. They may only be substituted to satisfy pecuniary awards from the deceased’s estate, protecting heirs from unlimited liability while preserving victims’ right to recover quantifiable losses.