The past three decades have seen third-party practice in Virginia instituted, abolished and revived. The practice was first sanctioned by a 1948 amendment to the Virginia Code of 1919. In the 1949 case of Masters v. Hart, it was held that by virtue of the 1948 amendment the trial court could, in its discretion, permit third parties to be impleaded as the interests of justice may require. However, the supreme court in that decision also pointed out that the amendment was both confusing and incomplete; and, also noted that in order for a complete system of third-party practice to be adopted the statute would have to be clarified by general rules of court or appropriate legislation.
John M. Claytor,
The Status of Third-Party Practice in Virginia,
U. Rich. L. Rev.
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