Court Rules Permanent Lok Adalats Lack Jurisdiction Over Service Matters Not Classified as Public Utility Services Under Legal Services Authorities Act, 1987
In a significant judgment delivered on August 11, 2026, the Rajasthan High Court, presided over by Justice Anoop Kumar Dhand, quashed an award passed by the Permanent Lok Adalat (PLA), Merta, District Nagaur, that directed the State of Rajasthan to grant service benefits to an employee from the date of his initial appointment. The court held that the PLA lacked jurisdiction to adjudicate service matters, as such disputes do not fall within the ambit of “public utility services” as defined under Section 22A(b) of the Legal Services Authorities Act, 1987.
The case arose when the respondent, Mr. Bhanwar Lal Jain, initially appointed as a Helper on a temporary basis in 1978, sought to have his service benefits counted from the date of his initial appointment rather than the date recognized by the employer, which was in 1981. After failing to secure these benefits through the department, he approached the Permanent Lok Adalat under Section 22B of the Act, seeking an order to extend his service benefits retrospectively.
The Permanent Lok Adalat entertained and allowed his application, directing the State authorities to comply with the relief sought. However, the State of Rajasthan challenged this award before the High Court through a writ petition under Article 226 of the Constitution of India, contending that the PLA did not have jurisdiction to hear service-related disputes.
Upon hearing, the High Court thoroughly examined the statutory provisions of the Legal Services Authorities Act, particularly Sections 22A, 22B, and 22C, which govern the establishment, jurisdiction, and procedural conduct of Permanent Lok Adalats. The court emphasized that PLAs are constituted to resolve disputes relating exclusively to public utility services such as transport, postal services, power supply, sanitation, hospitals, and insurance services.
Justice Dhand noted that service matters, including grant of service benefits, do not constitute public utility services under Section 22A(b) and therefore fall outside the jurisdiction of the PLA. The court held that the PLA had exercised power not vested in it by entertaining and deciding a service matter, thereby rendering the award unsustainable and liable to be quashed.
While quashing the award, the court granted liberty to the respondent to pursue his grievance through the appropriate departmental or judicial forum. The court directed the petitioner-authority to consider any application filed by Mr. Jain sympathetically and expeditiously within two months, passing a reasoned order. If dissatisfied, the respondent remains free to approach the competent forum for further redressal.
The judgment reinforces the limited jurisdiction of Permanent Lok Adalats and clarifies that service disputes must be resolved through established service grievance mechanisms or judicial forums, and not through PLAs. This ruling is expected to prevent similar jurisdictional overreach by PLAs in the future and ensure adherence to statutory mandates under the Legal Services Authorities Act.
Bottom Line:
Permanent Lok Adalat does not have jurisdiction to decide service matters, as they do not fall under the ambit of "public utility services" defined under Section 22A(b) of the Legal Services Authorities Act, 1987.
Statutory provision(s):
Legal Services Authorities Act, 1987 Sections 22A(b), 22B, 22C
State of Rajasthan v. Bhanwar Lal Jain, (Rajasthan) : Law Finder Doc Id # 2967040
