The Supreme Court has clarified that an award issued by a Lok Adalat under the Legal Services Authorities Act, 1987 cannot be annulled or interfered with by an Executing Court. The only permissible route to challenge such an award is by invoking the High Court’s supervisory powers under Article 227 of the Constitution.

Emphasising the finality attached to Lok Adalat awards, a Bench of Justices Vikram Nath and Sandeep Mehta observed that these awards, though executable as decrees, cannot be reopened through ordinary civil remedies. “The statutory finality of a Lok Adalat award excludes any appellate or civil challenge. While it may be executed like a decree, its validity cannot be questioned through civil suits or by resorting to collateral proceedings. The sole recognised avenue of challenge remains the High Court’s exceptional supervisory jurisdiction,” the Court held, while overturning the MP High Court’s refusal to entertain a writ petition challenging a compromise decree passed by the Jabalpur Lok Adalat.

The High Court had rejected the appellant’s writ petition on the ground that he had already filed objections under Order XXI Rule 101 CPC before the Executing Court.

Terming the High Court’s reasoning flawed, the Supreme Court said:
“Once the decree in question simply reflects a Lok Adalat award under the LSA Act, the Executing Court’s role is limited to implementing that award. It cannot nullify or question the award or the compromise underlying it. Treating objections in execution as an ‘effective alternative remedy’ is contrary to the statutory framework.”

Restoring the matter to the High Court, the Supreme Court reiterated that once a Lok Adalat award is passed, ordinary civil remedies are barred, and the aggrieved party must approach the High Court through a writ petition.

“We accordingly hold that the appellant’s writ petition challenging the Lok Adalat decree dated 14.05.2022 was maintainable, and the High Court erred in declining to examine it on the ground of an alleged alternative remedy,” the Court concluded.

Appearances:

For the Petitioner(s):
Mr. Siddharth Bhatnagar, Sr. Adv., Mr. Siddharth R Gupta, Adv., Mr. Sankalp Kochar, Adv., Mr. Siddhant Kochar, Adv., Mr. Mrigank Prabhakar, AOR, Mr. Aman Agarwal, Adv., Mr. Uddaish Palya, Adv., Mr. Aditya Sidhra, Adv., Ms. Surbhi Saxena, Adv., Mr. Siddharth Sahu, Adv., Ms. Astha Singh, Adv., Mr. Nr Shwetabh, Adv.

For the Respondent(s):
Mr. Ravindra Shrivastava, Sr. Adv., Mr. Abhijeet Shrivastava, AOR, Mr. Anshuman Shrivastava, Adv., Mr. Malik Arjun Khare, Adv., Ms. Shruti Verma, Adv., Ms. Ananya Sahu, Adv., Mr. Boudhik Garg, Adv., Mr. Shashank S Dwivedi, Adv., Mr. Atharva Joshi, Adv., Ms. Kavya Verma, Adv., Mr. Pallav Sishodiya, Sr. Adv., Mr. Kunal Verma, AOR, Mrs. Yugandhara Pawar Jha, Adv., Ms. Yasha Goyal, Adv., Ms. Swati Mishra, Adv., Mr. A. K. Sanghi, Sr. Adv., Mr. V. Sridhar Reddy, Adv., Mr. Abhijit Sengupta, AOR, Mr. Hardeep, Adv., Mr. Deepak Bahl, Adv.

Cause Title: DILIP MEHTA v. RAKESH GUPTA & ORS.