Lok Adalat Has No Jurisdiction To Decide A Matter On Merits: SC

1. Nature of Lok Adalat

Lok Adalats are alternative dispute resolution (ADR) forums.

They aim to reduce the burden on regular courts by providing a speedy and amicable settlement.

Proceedings are informal, non-adversarial, and based on conciliation, not adjudication.

2. Jurisdiction of Lok Adalat

Lok Adalat can take up:

Cases pending in court.

Cases at pre-litigation stage, if parties agree.

Powers:

They can only persuade the parties to settle.

Once a settlement is reached, the award has the status of a civil court decree (binding and final).

Limitations:

If no compromise is reached, Lok Adalat must return the case to the court.

It cannot adjudicate or decide disputes on the basis of merits like a court of law.

3. Key Case Laws

State of Punjab v. Jalour Singh (2008)

Supreme Court held that a Lok Adalat cannot decide disputes on merits.

Its only role is to record a settlement if both parties agree.

If parties don’t consent, the matter should go back to the regular court.

InterGlobe Aviation Ltd. v. N. Satchidanand (2011)

Court observed that Lok Adalat’s function is conciliation, not adjudication.

An award without mutual consent is without jurisdiction and invalid.

K.N. Govindan Kutty Menon v. C.D. Shaji (2012)

Lok Adalat award is binding only if it is based on compromise.

If the case is decided without consent, the award is a nullity.

Afcons Infrastructure Ltd. v. Cherian Varkey Construction Co. (2010)

Distinguished between different ADR mechanisms.

Reaffirmed that Lok Adalat lacks adjudicatory power unlike arbitration or courts.

4. Supreme Court’s Principle

Lok Adalat is a conciliation forum.

It cannot:

Examine evidence.

Apply legal principles to decide who is right or wrong.

Give judgment on merits.

It can only:

Facilitate settlement.

Record compromise.

Pass an award equivalent to a decree only when parties agree.

5. Practical Implication

Parties cannot be forced into an award by Lok Adalat.

If one party disagrees:

The matter is sent back to the referring court.

Thus, Lok Adalat is effective only for consensual settlements, not for adjudicating disputes.

In summary:
The Supreme Court has made it clear that a Lok Adalat cannot function like a regular court. It has no jurisdiction to decide matters on merits. Its award is valid only when it is the result of a voluntary compromise between the parties. Otherwise, the case returns to the regular judicial system.

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