Supreme Court Upholds Limited Challenge Scope for Lok Adalat Awards Lok Adalat awards can only be contested through writ petitions on specified grounds, not via execution or civil suits.
In a significant ruling, the Supreme Court of India has reiterated the sanctity and finality of Lok Adalat awards, emphasizing that challenges to such awards can only be made through writ petitions under Articles 226 and 227 of the Constitution of India. The judgment in the case of Dilip Mehta v. Rakesh Gupta, delivered on November 18, 2025, clarified that Lok Adalat awards, deemed as decrees of civil courts, are not subject to annulment by executing courts or through civil suits.
The appellant, Dilip Mehta, had sought to contest a Lok Adalat decree dated May 14, 2022, on grounds of alleged fraud and collusion. The Supreme Court, consisting of Justices Vikram Nath and Sandeep Mehta, observed that the statutory framework under the Legal Services Authorities Act, 1987, provides that Lok Adalat awards are final and binding, with no scope for appeal in civil proceedings. The proper avenue for contesting such awards is through writ jurisdiction, reserved for exceptional cases such as fraud or lack of consent.
The Court criticized the approach of the Madhya Pradesh High Court, which had previously dismissed Mehta's writ petition, asserting that the appellant could not pursue parallel proceedings after filing objections in execution. The Supreme Court clarified that objections in execution are defensive measures and do not constitute an alternative remedy for challenging the Lok Adalat award itself.
The judgment underscored the legislative intent of ensuring that Lok Adalat awards achieve finality and are only executable as decrees, without reopening their validity in civil suits. The Court directed the High Court to reassess the writ petition filed by Mehta on its merits, while noting that executing courts lack jurisdiction to annul Lok Adalat awards.
Bottom Line:
Lok Adalat awards under the Legal Services Authorities Act (LSA Act) cannot be annulled by an Executing Court. The only proper remedy to challenge such awards is a writ petition before the High Court under Articles 226 and 227 of the Constitution of India.
Statutory provision(s): Articles 226 and 227 of the Constitution of India, Legal Services Authorities Act, 1987 Sections 21, 22E, Civil Procedure Code, 1908 Order XXI Rules 97, 99, and 101
Dilip Mehta v. Rakesh Gupta, (SC) : Law Finder Doc Id # 2820018
