Bank Mart v. Langley

The above entitled cases come before this court with the common underlying issue of whether service by newspaper publication is sufficient. Statutes which allow notice by publication are usually permissive. See, e.g., General Statutes § 52-68. It is generally accepted practice in Connecticut that when a defendant cannot be found, the plaintiff will seek an order for notice by publication without establishing that other forms of service can be made.

For example, in the above Langley cases (foreclosure of a mortgage) an attempt was made to serve the defendant owner by registered mail in North…