Does a third party have the right to pursue a separate, plenary action in the bankruptcy court?

6 In such situations, the third party "claimant has the right to have the merits of his claim passed on in a plenary suit" in a court that independently has in rem jurisdiction over the subject matter. Cline, 323 U.S. at 99, 65 S.Ct. at 156. Thus, under the Bankruptcy Act, even where the trustee claims an interest in the res, a separate, plenary action "in any court of proper jurisdiction" is the only means of adjudicating title to the property. See, e.g., Harrison v. Chamberlin, 271 U.S. 191, 193, 46 S.Ct. 467, 468, 70 L.Ed. 897 (1926) (collecting cases).