The Supreme Court recently ruled that an award passed by a Lok Adalat under the Legal Services Authorities Act, 1987 cannot be challenged or set aside through ordinary civil remedies in the executing court. The Court observed that once a Lok Adalat award is recorded, it enjoys statutory finality and becomes executable as a decree. However, its validity cannot be reopened or annulled in subsequent civil proceedings by treating execution-stage objections or a fresh suit as appropriate vehicles for challenge. The only proper method for a dissatisfied party to challenge such award is by invoking the supervisory jurisdiction of the relevant High Court under constitutional provisions, specifically under Article 227 of the Constitution of India.
The matter before the Court involved a decree derived from a compromise passed by a Lok Adalat. The aggrieved party had moved the High Court via writ petition challenging the award. The High Court had refused to entertain the petition on the ground that the party had already filed objections under Order XXI Rule 101 of the Code of Civil Procedure before the executing court. The Supreme Court held that this approach was mistaken. Once the decree sought to be executed is merely representative of a Lok Adalat award, the executing court — which would otherwise have the power to pass execution orders — lacks authority to annul or set aside the award itself. The Court clarified that objections filed under civil execution procedure in such cases cannot be treated as an “efficacious alternative remedy.”
By its order, the Court set aside the High Court’s refusal to consider the writ petition. It remanded the matter back to the High Court for reconsideration, directing that the challenge to the Lok Adalat award should be examined on merits under its supervisory jurisdiction, rather than rejected on account of availability of a civil execution remedy.
In its reasoning, the Court explained that the statutory scheme under the Legal Services Authorities Act attaches a special finality to Lok Adalat awards. Once parties settle a dispute before Lok Adalat and the settlement is recorded, it gains the status of an enforceable civil decree. But the rationale for such finality also imposes limits: ordinary civil suits or execution stage objections cannot reopen or question the validity of the compromise underlying the award. That would circumvent the scheme’s finality. Therefore, to protect the interests of all parties and ensure that only exceptional, constitutionally valid challenges succeed, the Court confined the remedy to writ jurisdiction under supervisory power of the High Court.
This decision underscores that not every dispute over a Lok Adalat award can be ventilated before civil courts or via execution proceedings. Only when a party files a writ petition under Article 227 (or Article 226, as the case may be) raising legitimate grounds — such as fraud, misrepresentation, or denial of natural justice — can the High Court reassess the award. The Supreme Court’s ruling reaffirms long-standing jurisprudence that respects both the finality of amicable settlements through Lok Adalat and the need for an extraordinary but constitutionally backed mechanism to correct manifest injustice or abuse of process.
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