Statutory Finality of Lok Adalat Award Leaves No Room for Appellate or Plenary Civil Remedy: Supreme Court

The Supreme Court has reiterated the legal position that a Lok Adalat award under the Legal Services Authorities Act, 1987 attains statutory finality and cannot be reopened through ordinary civil remedies. The Court held that when a decree sought to be executed merely embodies a Lok Adalat award, the executing court’s role is confined to giving effect to the award through execution and it cannot annul, set aside, or sit in judgment over the award or the underlying compromise.

The ruling was delivered by a bench of Justice Vikram Nath and Justice Sandeep Mehta in Dilip Mehta v Rakesh Gupta and Others. The Supreme Court allowed the appeal against the Madhya Pradesh High Court’s orders which had declined to examine a writ petition challenging a Lok Adalat decree on the ground that the petitioner had already filed objections before the executing court.

Background of the dispute

The appellant, Dilip Mehta, challenged a compromise decree dated May 14, 2022 passed by the Lok Adalat at Jabalpur and the consequential execution proceedings. The appellant had approached the Madhya Pradesh High Court by way of a writ petition seeking to assail the Lok Adalat decree. The High Court dismissed the writ petition and the subsequent intra court appeal on the reasoning that since objections had been filed in execution proceedings, an efficacious alternative remedy existed and the writ petition should not be entertained.

Before the Supreme Court, the central issue was whether the High Court was justified in refusing to entertain the appellant’s challenge to a Lok Adalat decree on the basis that the appellant had already invoked execution objections under Order XXI provisions of the Code of Civil Procedure, 1908.

Supreme Court on finality of Lok Adalat awards

The Supreme Court examined the statutory scheme governing Lok Adalat awards, including Section 21 of the Legal Services Authorities Act, 1987, which provides that every award of a Lok Adalat is deemed to be a decree of a civil court, is final and binding on the parties, and that no appeal lies against it. The Court also referred to Section 22E, which deals with awards of Permanent Lok Adalats and states that such awards are final, deemed to be decrees of civil courts, and shall not be called in question in any original suit, application, or execution proceeding.

The bench held that both provisions reflect a common legislative intent that Lok Adalat awards attain finality and are not appealable in the ordinary sense. A Lok Adalat award operates as a decree only for the limited purpose of execution, and this statutory structure restricts collateral civil challenges.

The Supreme Court further reiterated earlier precedent, including State of Punjab v Jalour Singh (2008) and Bhargavi Constructions v Kothakapu Muthyam Reddy (2018), to emphasise that the recognised avenue to challenge a Lok Adalat award is through the constitutional jurisdiction of the High Court under Articles 226 and 227 on limited grounds such as lack of consent, jurisdictional error, or fraud.

Executing court cannot set aside a Lok Adalat award

A key holding of the Supreme Court was that once the decree sought to be executed merely embodies a Lok Adalat award, the executing court is confined to giving effect to the award in execution. The executing court has no authority to annul or set aside the award itself or the decree drawn in its terms, and cannot examine the validity of the compromise on which the Lok Adalat proceeded.

The Court held that treating objections raised in execution as an efficacious alternative remedy for challenging a Lok Adalat award is inconsistent with the statutory scheme. The form of a pleading cannot expand the executing court’s jurisdiction and cannot convert an execution forum into an appellate forum over a Lok Adalat award.

Order XXI objections and their limited scope in Lok Adalat decrees

The Supreme Court addressed the High Court’s reliance on Order XXI Rules 97, 99 and 101 of the CPC. It clarified that in the specific context of a decree reflecting a Lok Adalat award, these provisions enable the executing court to address incidental questions arising while working out execution, such as whether and to what extent the decree can be enforced against a person in possession and the manner of enforcement. However, these provisions do not authorise the executing court to reopen the settlement resulting in the award, examine the validity of the award, or declare the decree void.

The Court also held that Section 22E(4), which states that an award shall not be called in question in any original suit, application or execution proceeding, operates as a prohibitory clause reinforcing the bar against collateral civil challenges. It does not enlarge the jurisdiction of the executing court to invalidate such awards even at the instance of a third party objector.

High Court’s approach set aside, matter remanded

After clarifying the legal position, the Supreme Court held that the writ petition filed by the appellant to assail the Lok Adalat decree was maintainable. The High Court was not justified in declining to examine it on the ground of an alternative remedy in execution proceedings.

The bench held that the High Court’s judgments were based on an incorrect understanding of the scope of Section 22E of the Legal Services Authorities Act and the reach of Order XXI Rules 97, 99 and 101 CPC with respect to Lok Adalat awards, and were inconsistent with the law declared by the Supreme Court in the earlier decisions referred to in the judgment.

Accordingly, the Supreme Court set aside the impugned High Court judgments and remanded the matter back to the High Court for hearing and decision afresh on merits in accordance with law, with an expectation of expeditious disposal.

The Supreme Court directed the appellant to withdraw the objections filed under Order XXI Rule 101 read with Section 151 CPC in the execution case within four weeks. Until the High Court finally disposes of the matter, the Supreme Court directed that the appellant shall not be dispossessed from the property in question

Case Title: Dilip Mehta v Rakesh Gupta and Others

Court: Supreme Court of India

Bench: Justice Vikram Nath and Justice Sandeep Mehta

Date of Judgment: November 18, 2025