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Estate Officer v. Colonel H.V. Mankotia (Retired)

Civil Appeal · 2021 INSC 635Decided 7 Oct 2021
Civil Appeal No. 6223 of 2021
Justice M.R. Shah · Justice A.S. Bopanna

Background

The respondent had filed a writ petition before the Madhya Pradesh High Court, which was listed before a Lok Adalat for a possible settlement. Instead of simply trying to broker a compromise, the Lok Adalat went on to examine the merits of the case itself and dismissed the writ petition outright. The respondent's attempt to get the matter restored before the High Court also failed, leading to this appeal before the Supreme Court.

Decision Breakdown

The Court held that under Sections 19 and 20 of the Legal Services Authorities Act, 1987, a Lok Adalat's jurisdiction is strictly limited to helping parties reach a compromise or settlement: it has no power to adjudicate a case on its merits. Once it becomes clear that no settlement is possible, the Lok Adalat must return the matter to the court from which it came, for that court to decide it according to law. Relying on its earlier ruling in State of Punjab v. Ganpat Raj, the Court found the Lok Adalat's order dismissing the writ petition on merits to be wholly without jurisdiction, quashed it, and restored the writ petition to the High Court for a proper decision on merits.

Lesson Learnt

A Lok Adalat exists only to facilitate a mutually agreed settlement between parties: it cannot decide the rights and wrongs of a case the way a regular court does; if no settlement is reached, the case must go back to the original court for a decision on its merits.

Official source (sci.gov.in)View Judgment (PDF)

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