A Lok Adalat award cannot be set aside on bald, unsubstantiated allegations of fraud.

Respondent No. 4 instituted a partition suit against his parents, brothers and the petitioner, his sister.

On 5 October 2013, the petitioner and the other parties, with their respective counsel, signed a joint memo reporting settlement and seeking reference to the Lok Adalat. On 24 October 2013, the parties presented a compromise petition before the Lok Adalat, which passed an award recording the settlement.

The petitioner later alleged that she had been hurried into signing without understanding the terms, that the settlement denied her a proper share, and that the respondents had not complied with it.

She had separately sought to set aside the award and claim partition, but the plaint was rejected and the rejection was upheld in revision; she then challenged the award under Articles 226 and 227.

The High Court found that she had not disclosed her earlier appearance at Raichur on 5 October 2013, when she signed the joint memo.

Whether the petitioner established that the Lok Adalat award was obtained by fraud or misrepresentation so as to warrant interference under Articles 226 and 227

Whether alleged non-compliance with the compromise terms was a ground to set aside the award

Under Section 21 of the Legal Services Authorities Act, 1987, a Lok Adalat award has the status and enforceability of a decree.

A challenge to such an award by writ petition may be maintainable, including on an allegation of fraud, but the award cannot be set aside merely on assertion; fraud must be specifically pleaded and strictly proved with supporting material.

The court also relied on the principle that a compromise decree is ordinarily treated as an agreement with the court’s approval and that non-compliance with an enforceable decree is ordinarily addressed through execution, not by setting the decree aside.

The Court found that the petitioner had signed the joint memo reporting settlement on 5 October 2013, appeared with the parties and counsel before the Lok Adalat on 24 October, and signed the compromise petition.

It also noted that she later furnished stamp paper and obtained the award engrossed on stamp paper. These circumstances, together with her failure to disclose the earlier appearance and the absence of specific pleadings or corroborative material, did not support her allegations of fraud or misrepresentation.

Her allegation that the respondents had not performed the settlement was unsupported by pleadings or evidence and, in any event, did not justify setting aside the award; the award could be enforced as a decree.

The writ petition was dismissed.