Andhra Pradesh High Court Upholds Execution of Lok Adalat Award Despite Non-Adherence to Settlement Terms in Separate Suit

Court dismisses petition challenging execution based on unrelated settlement breach, reinforcing the finality of Lok Adalat awards.

In a significant judgment, the Andhra Pradesh High Court has dismissed a petition challenging the execution of a Lok Adalat award, emphasizing the binding nature of such awards despite non-compliance with settlement terms in a separate, unrelated suit. The decision was delivered by Justice Sri Ravi Nath Tilhari in the matter of Nethipadi Swarnalatha v. Maradana Seshagiri Rao, concerning a Civil Revision Petition No. 2928 of 2025.

The petitioner, Nethipadi Swarnalatha, who is the judgment debtor in the original suit O.S.No.215 of 2021, argued against the execution of the Lok Adalat award that was passed on November 12, 2022, following a compromise between the parties. The contention was based on the plaintiff's alleged failure to adhere to a settlement clause in a different suit, O.S.No.220 of 2022, which involved the petitioner's brother and was pending in the III Additional Junior Civil Judge, Visakhapatnam.

The petitioner's counsel, T.S.B.V. Rama Reddy, highlighted that according to clause (3) of the settlement, the plaintiff had agreed not to pursue O.S.No.220 of 2022 on the date fixed for November 3, 2022. Contrary to this agreement, the said suit was not withdrawn but was dismissed on its merits. The petitioner argued that this breach should prevent the execution of the Lok Adalat award in O.S.No.215 of 2021.

Justice Tilhari, however, found no merit in this argument, clarifying that the two suits involved different parties and subject matters. The claim in O.S.No.220 of 2022 was based on different promissory notes and did not concern the same defendant as in O.S.No.215 of 2021. The court underscored that the Lok Adalat award, being final and binding on the parties involved in that specific suit, remains executable irrespective of proceedings in a separate suit.

The court concluded that the failure to adhere to the settlement terms in O.S.No.220 of 2022 does not affect the enforceability of the award in O.S.No.215 of 2021. Consequently, the petition was dismissed, and the execution proceedings were allowed to continue, reaffirming the integrity and finality of Lok Adalat settlements.

No other arguments were presented, and the court saw no illegality in the execution court's order. The decision highlights the judiciary's stance on upholding the sanctity of Lok Adalat awards and their execution, providing clarity on the separation of obligations arising from different legal suits.

Bottom Line:

Execution of Lok Adalat award cannot be denied on the ground that terms of settlement involving a different suit and different parties were not adhered to.

Statutory provision(s): Civil Procedure Code, 1908 Order XXI Rules 54, 64 to 66

Nethipadi Swarnalatha v. Maradana Seshagiri Rao, (Andhra Pradesh) : Law Finder Doc Id # 2812851