A Lok Adalat award procured by concealing existing third-party rights is liable to be set aside.

Selvaraj filed O.S. No. 610 of 2020 seeking partition of the suit properties.

After his death, his mother was transposed as plaintiff.

The parties entered into a compromise before the Lok Adalat, which passed an award on 18 February 2022; the award was registered as Document No. 2368 of 2022 on 7 March 2022.

The revision petitioners claimed rights in the properties and alleged that the suit and compromise concealed prior dealings and transfers to third parties, whose rights were thereby affected without their participation.

They challenged the award under Article 227 of the Constitution.

Whether the revisions under Article 227 were maintainable to challenge the Lok Adalat award.

Whether the award should be set aside on the ground that the compromise was obtained through a collusive suit that concealed existing third-party rights.

Whether the suit should be remitted for further proceedings, and on what terms.

The Court stated that a Lok Adalat award may be challenged only by a petition under Article 227 of the Constitution of India, relying on Dilip Mehta v. Rakesh Gupta and others, 2025 SCC OnLine SC 2737.

The judgment identifies no further statutory provision or legal test; it proceeds on the principle that an award procured through fraud or concealment of material facts, in circumstances affecting existing third-party rights, cannot stand.

The Court found that the petitioners had placed overwhelming material showing that the suit properties had already been dealt with and that third-party rights had arisen before the compromise.

The contesting respondents provided no explanation for compromising the suit without addressing those rights, and their counsel indicated that they had no further instructions.

In those circumstances, the Court held the award and its registration illegal and non est.

It also concluded that any continuation of the suit required the participation of all necessary parties.

The Court remitted O.S. No. 610 of 2020 to the IV Additional District Court, Coimbatore.

Any party wishing to contest the suit must take steps to implead all necessary parties within eight weeks of receiving the order; otherwise, the trial court must close the suit for non-prosecution.

No costs were ordered, and the connected miscellaneous petitions were closed.