The law on Lok Adalat Award Remedy receives sharp judicial clarity as the Supreme Court speaks unequivocally on the boundaries of civil courts in relation to awards passed under the Legal Services Authorities Act 1987.
The ruling dismantles the belief that objections under the Civil Procedure Code or a collateral civil action can unsettle a Lok Adalat settlement once it is drawn as a decree.
A Bench of Justice Vikram Nath and Justice Sandeep Mehta held that an Executing Court cannot annul, modify or reopen the validity of a Lok Adalat award.
The Court underscored that the only lawful remedy to challenge such an award is to invoke the High Court’s supervisory jurisdiction under Article 227 of the Constitution.
All other civil remedies stand excluded because the statute grants finality to such awards.
High Court Erred In Treating Execution Objections As Alternative Remedy
The Madhya Pradesh 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. The Supreme Court found this approach fundamentally flawed.
The Bench observed that when a decree only embodies a Lok Adalat award, the Executing Court’s role is strictly limited to enforcement. It cannot review the compromise, test its validity or set aside the decree.
Therefore, treating execution objections as an adequate alternative remedy contradicts the statutory scheme of the LSA Act.
The Court emphasised that Lok Adalat awards enjoy statutory finality and acquire the status of a civil court decree only for execution purposes, not for reopening the compromise.
Supervisory Jurisdiction, Not Civil Litigation, Is The Proper Avenue
The judgment reiterates an important principle for practitioners:
Once a Lok Adalat award is passed, civil courts have no plenary jurisdiction to examine its correctness.
The Supreme Court remanded the matter back to the High Court with a direction to hear the writ petition on its merits, holding that the petition was maintainable.
The Court explained that the architecture of the LSA Act excludes ordinary civil challenges because Lok Adalats function as consensus-based resolution forums, and the sanctity of such settlements cannot be casually undermined.
Why This Ruling Matters For Practitioners
- Any challenge to a Lok Adalat Award Remedy must be channelled only through Article 227, not through execution objections or independent suits.
- Executing Courts lack jurisdiction to question validity of Lok Adalat settlements.
- High Courts cannot decline writ remedy on the basis of such objections being an alternative remedy.
This ruling has substantial implications for property disputes, motor accident claims, commercial settlements and matrimonial compromises settled before Lok Adalats.
Lok Adalat Award Remedy Reaffirmed By Supreme Court In Dilip Mehta Versus Rakesh Gupta
The Supreme Court’s reiteration that the Lok Adalat Award Remedy flows exclusively through Article 227 brings much needed discipline and clarity to the practice of execution and challenge mechanisms under the LSA Act.
No ordinary civil action can undo a compromise decree derived from a Lok Adalat award.
Party and Bench Details
- Case Title: Dilip Mehta versus Rakesh Gupta and Others
- Bench: Justice Vikram Nath and Justice Sandeep Mehta
- Date: 10 December 2025
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Dilip Mehta versus Rakesh Gupta and Others
