In fact, the Housing Court Act itself (CCA, § 110), provides in pertinent part: “(d) In any of the actions or proceedings specified in subdivision (a) and on the application of any party, any city department or the court, on its own motion, may join any other person or city department as a party in order to effectuate proper housing maintenance standards and to promote the public interest.”
This section authorizes joinder “on the most, liberal of terms, enhancing the court’s potential as a source of novel and wide-ranging solutions to problems of housing maintenance. Unfortunately, this provision has been infrequently invoked and thus [is] of little benefit” (Rutzick & Huffman, The New York City Housing Court: Trial and Error in Housing Code Enforcement, 50 NYU L Rev 738, 765-766).
One of the reasons for such lack of use may be that no specific provision exists in the RPAPL for a third-party order incorporating a third-party judgment in a “final judgment” (see Gorman v Gorman, 77 Misc 2d 687, 688, and Edaviel Corp. v Boykin, supra, at p 623). However, subdivision [d] of section 110 of the CCA clearly represents legislative creation of a statutory remedy for joining additional persons or municipal departments as parties in a summary proceeding.