Connecticut General Statutes

Conn. Gen. Stat. § 52-101 (2026)

Joinder of interested persons as plaintiffs

✓ current as of May 2026

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All persons having an interest in the subject of a civil action, and in obtaining the judgment demanded, may be joined as plaintiffs, except as otherwise expressly provided; and, if one who ought to be joined as plaintiff declines to join, he may be made a defendant, the reason therefor being stated in the complaint.

(1949 Rev., S. 7823; P.A. 82-160, S. 37.)

History: P.A. 82-160 added the words “a civil” before “action”.

Practice act is liberal in respect to parties; 52 C. 235; technical rules abolished. 81 C. 127. When same individual cannot sue as executor and as trustee. 60 C. 399. Cited. 63 C. 476. Several beneficiaries unequally interested may unite to recover damages for the conversion of a single trust fund. 65 C. 556. Ordinarily, plaintiffs may join at will and should not be stricken out without their consent. 72 C. 478. Shareholders in corporation may join in tax appeal where interests are identical. 73 C. 288. When taxpayers appealing from former board of relief may be joined. Id., 293. Parties beneficially but unequally interested in estate may join with administratrix in foreclosing judgment lien. 75 C. 154. Creditors of dissolved corporation properly joined as plaintiffs in action to enforce stockholder's liability. 78 C. 596. Owners abutting on highway may join in action to prevent its obstruction. 79 C. 359. Various certificate holders in safety fund of insurance company properly joined in equitable action to enforce their rights. 80 C. 702. Owner of property proper plaintiff in summary process, though action is brought in behalf of one who has agreed to purchase it. 94 C. 452. Where taxpayer appeals from board of relief because another's property was not assessed at all, such other is a necessary party defendant. 109 C. 361. A mortgagee and one to whom the mortgage has been pledged as security for a debt of less amount than the mortgage may join as coplaintiffs in action to foreclose. 111 C. 111. Cited. 145 C. 191; 146 C. 570. Legislative policy of Secs. 52-101 to 52-110 is in favor of speeding justice. 154 C. 455.

Cited. 7 CA 613.

Who are proper parties to set aside a deed alleged to have been executed under undue influence and mental incapacity. 16 CS 212. Cited. 44 CS 569.

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Notes of Decisions

Cited in 7 cases, 1959–2016 · leading case: Stocker v. City of Waterbury, 226 A.2d 514 (Conn. 1967).

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Stocker v. City of Waterbury, 226 A.2d 514 (Conn. 1967). · cites it 4× “Our statutes providing for the joinder of parties (General Statutes §§ 52-10152-110) and permitting class actions are expressions of a legislative policy in favor of speedier justice.”

Franco v. East Shore Dev., Inc., 858 A.2d 703 (Conn. 2004). · cites it 4× “Laurel Woods, as the assignee of East Shore, sought pursuant to General Statutes §§ 52-101 3 and 52-103 4 to be joined as a party in interest to the *627 proceedings.”

Walsh v. Nat'l Saf. Assocs., Inc., 695 A.2d 1095 (Conn. Super. Ct. 1996). · cites it 2× “Alternatively, the class appears to be too numerous for an effective joinder pursuant to Practice Book § 85 and General Statutes §§ 52-101 and 52-102. Joinder in the form of voluntary opting-in was tried in State v.”

Purtill v. Town Plan & Zoning Comm'n, 153 A.2d 441 (Conn. 1959). “1958, §§ 52-101, 52-104. There is no error. In this opinion the other judges concurred.”

Shorehaven Dodge, Inc. v. Costa, 509 A.2d 1082 (Conn. App. Ct. 1986). · cites it 2× “3 General Statutes § 52-101 provides in pertinent part: “All persons having an interest in the subject of a civil action .”

Franco v. East Shore Dev., Inc., 807 A.2d 1039 (Conn. App. Ct. 2002). · cites it 4× “Laurel Woods, as the assignee of East Shore, sought pursuant to General Statutes §§ 52-101 and 52-103 to be joined as a party in interest to the proceedings.”

Fairfield Merrittview Ltd. P'ship v. Norwalk (Conn. 2016). · cites it 3× “Thereafter, the partner- ship filed a motion for permission to amend its appeal and application to add the LLC as a party plaintiff with ‘‘an interest in the real estate’’ pursuant to General Statutes § 52-101 (providing for joinder of interested parties) and Practice Book § 9-3…”

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