Connecticut General Statutes

Conn. Gen. Stat. § 52-107 (2026)

Additional parties may be summoned in

✓ current as of May 2026

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The court may determine the controversy as between the parties before it, if it can do so without prejudice to the rights of others; but, if a complete determination cannot be had without the presence of other parties, the court may direct that such other parties be brought in. If a person not a party has an interest or title which the judgment will affect, the court, on his application, shall direct him to be made a party.

(1949 Rev., S. 7829; P.A. 82-160, S. 43.)

History: P.A. 82-160 rephrased the section.

See Sec. 52-484 re interpleader.

Cited. 24 C. 384; 33 C. 467. Stranger cannot be cited in to secure adjudication of claim not involved in action. 50 C. 583; 65 C. 76; 67 C. 277; 76 C. 542; 79 C. 694; 81 C. 474; 85 C. 429. Holder of mortgage bonds of street railway company not entitled to be made a codefendant in action against it. 56 C. 398. Complaint against one as administrator may be amended to charge him in his individual capacity. 57 C. 304. Taxing communities may be admitted as coplaintiffs with tax collector. 60 C. 118. This and related sections have radically changed the old practice. 63 C. 476. Cited. 65 C. 115. Application to cite in receiver properly refused, if permission to sue him has not been obtained. 66 C. 277. Court may admit persons vitally interested, although not necessary parties. 68 C. 157. Discretion of court where motion has been long delayed. 69 C. 440. Cited. 72 C. 92. Process, not complaint, makes parties. Id., 261. If claim assigned during suit, assignee may be substituted as plaintiff; prima facie showing of interest sufficient. 73 C. 377. Street railway company, primarily liable for defect in highway, may come in as defendant in action for injury due to it. 74 C. 163. Court may permit executor to enter in action brought by testator after time fixed by statute. 77 C. 347. Waiver by executor who voluntarily enters to defend. Id., 382. Right of taxpayer to defend action against city. 81 C. 235. Validity of mechanic's lien cannot be determined in action to which landowner is not a party. 90 C. 7. Third party beneficiary may sue on contract made for his benefit; other necessary parties may be cited in. 99 C. 216. Where taxpayer's complaint in appeal from former board of relief is based on failure to list taxable property of other persons, they must be made parties defendant. 109 C. 361. In appeal from zoning board, proper to permit intervention of property owners claiming their property would be damaged in value by erection of gas tank. 113 C. 695. Liquor Control Commission, while it would have been a proper party to action by town against permittee, was not a necessary party. 133 C. 157. Cited. 153 C. 545; 172 C. 572; 182 C. 1; 184 C. 483; 185 C. 445; 186 C. 311; 191 C. 1; 206 C. 374; 212 C. 628; 215 C. 224; 224 C. 263; 239 C. 1; 241 C. 734. Trial court did not err in denying motion to intervene as a matter of right because the movant did not identify an interest of direct and immediate character that would cause it to gain or lose anything as a result of the judgment in the case, and did not err in denying permissive intervention because the movant failed to demonstrate that Attorney General's defense of constitutionality of the marriage laws would be inadequate. 279 C. 447.

Cited. 7 CA 613; 16 CA 124; 21 CA 67; 31 CA 476; 32 CA 340; 41 CA 89; 42 CA 330; judgment reversed, see 241 C. 734. Statutory language clearly and unambiguously conveys the meaning that section is applicable only in cases in which an action is presently pending before the court, and not in cases in which a judgment has been rendered. 196 CA 70. General contractors do not have an automatic right to intervene in an application to discharge a subcontractor's mechanics lien. 207 CA 649.

Cited. 6 CS 281. Purchasers of corporate real estate from the trustee in bankruptcy were entitled to be joined as parties defendant where general manager of corporation was without assets and in parts unknown. 12 CS 199. A party charged with liability may not bring in another party liable to indemnify him. 13 CS 461. Cited. 18 CS 106; 25 CS 315; 26 CS 418. Section may not be used by Probate Court party to become party to another's appeal; applicant who did not take appeal in time limited lost his right to appeal. 28 CS 392. Cited. 33 CS 606; 36 CS 56; 41 CS 23; Id., 389.

New parties may be cited in upon order of court at any time in the course of an action, provided they receive due notice and a reasonable time to prepare their particular claims or defenses; where additional parties were cited in as parties defendant, the moving papers served on them did not constitute a new civil action, process in which would be subject to provisions of Sec. 52-48a. 3 Conn. Cir. Ct. 321.

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Notes of Decisions

Cited in 58 cases (10 in the last 5 years), 1965–2026 · leading case: Webster Bank v. Zak, 792 A.2d 66 (Conn. 2002).

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Webster Bank v. Zak, 792 A.2d 66 (Conn. 2002). · cites it 6× “Thereafter, MFR moved to be cited in as a party defendant, pursuant to General Statutes § 52-107 and Practice Book § 9-6, claiming that it was “the record titleholder of the property that is the subject of the foreclosure, and any judgment of foreclosure will necessarily affect…”

Rosado v. Bridgeport Roman Catholic Diocesan Corp., 758 A.2d 916 (Conn. App. Ct. 2000). · cites it 11× “” Practice Book § 9-18 “is virtually identical to C.G.S.A. § 52-107, which has been in existence since it was adopted as § 15 of the 1879 Practice Act.”

State Bd. of Educ. v. City of Waterbury, 571 A.2d 148 (Conn. App. Ct. 1990). · cites it 11× “3 The appellants first contend that the trial court erroneously denied their motion to intervene because they should have been permitted to intervene as of right, and they cite General Statutes § 52-107 and Prac *70 tice Book § 99 4 as authority for this position.”

Rosado v. Bridgeport Roman Catholic Diocesan Corp., 884 A.2d 981 (Conn. 2005). · cites it 4× “[65] Rule 24 of the Federal Rules of Civil Procedure provides in relevant part: "(a) Intervention of Right.”

Franco v. East Shore Dev., Inc., 858 A.2d 703 (Conn. 2004). · cites it 9× “Treating the motion to join the confirmation proceeding as a motion to intervene pursuant to General Statutes § 52-107, 6 Chief Judge Lavery first noted his disagreement with the underlying assumption of the Appellate Court majority, namely, “that .”

Kerrigan v. Comm'r of Pub. Health, 904 A.2d 137 (Conn. 2006). · cites it 4× “Shortly after the plaintiffs filed the complaint, the institute moved, pursuant to General Statutes § 52-107, 4 and Practice Book § 9-18, 5 to intervene in the case as a matter of right, or in the alternative, permissively.”

Palmer v. Friendly Ice Cream Corp., 940 A.2d 742 (Conn. 2008). · cites it 4× “13 General Statutes § 52-107 14 governs the interven *479 tion of nonparties to a lawsuit and, unlike § 52-105, provides for both permissive intervention and intervention as a matter of right.”

Horton v. Meskill, 445 A.2d 579 (Conn. 1982). · cites it 3× “Practice Book § 99, which, is identical to General Statutes § 52-107, provides in full: “Sec.”

Ostrowski v. Avery, 703 A.2d 117 (Conn. 1997). · cites it 4× “1 On the motion of its special litigation committee, 2 Avery Abrasives became a *357 defendant 3 in accordance with General Statutes § 52-107. 4 The plaintiffs claimed that, by establishing International Small Wheels (ISW), a corporation engaged in the manufacture of small…”

Simko v. Zoning Bd. of Appeals, 538 A.2d 202 (Conn. 1988). · cites it 2× “Should the municipality decide, after having been properly cited and served with notice of the appeal, that its interests will be affected by the judgment rendered and will not be adequately represented by the board then the municipality may move, pursuant to General Statutes §…”

In re Baby Girl B., 618 A.2d 1 (Conn. 1992). · cites it 2× “” General Statutes § 52-107 contains essentially the same provisions as Practice Book § 99.”

Investors Mortg. Co. v. Rodia, 625 A.2d 833 (Conn. App. Ct. 1993). · cites it 5× “” Pursuant to General Statutes § 52-106, 1 The Investors Mortgage Company, as trustee, had the right to sue for a deficiency judgment without joining those benefi- *480 daily interested in the action.”

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