A Lok Adalat compromise award may be challenged only by writ petition, not by separate civil suit.

The respondents filed O.S. No. 919/2024 seeking a declaration that a judgment and decree in O.S. No. 1151/2023, stated to have been entered by compromise before a Lok Adalat, was null and void and not binding on them, as well as an injunction against the defendants

Defendant No. 1 sought rejection of the plaint under Order VII Rule 11 CPC, contending that Order XXIII Rule 3A barred a separate suit to challenge the compromise decree. The trial court dismissed the application, relying on *M.L. Vijaya v. T. Srinath* and distinguishing its circumstances

Defendant No. 1 challenged that order in this revision petition

1. Whether the trial court’s dismissal of the application under Order VII Rule 11 CPC should be set aside where the specific ground concerning the Lok Adalat award and the remedy available to the respondents had not been raised before that court

2. Whether the petitioner should be permitted to file a fresh application for rejection of the plaint, for the trial court to consider in light of the law governing challenges to Lok Adalat awards

Order VII Rule 11 CPC provides for rejection of a plaint on the grounds specified in that provision; the application must be considered on the grounds properly raised and the material relevant to that inquiry

Section 115 CPC limits the High Court’s revisional jurisdiction

Relying on *Dilip Mehta v. Rakesh Gupta & Ors.*, 2025 LiveLaw (SC) 1188, the Court noted that the validity of a Lok Adalat award is to be tested in writ proceedings before the High Court, rather than through an independent civil suit or an expanded execution inquiry

The Court did not finally determine whether the respondents’ suit was barred; it directed the trial court to consider that question on a fresh application and in light of the cited decision

The plaint averments indicated that the compromise had been entered before a Lok Adalat, and the petitioner relied on *Dilip Mehta* to contend that a writ petition, rather than a civil suit, was the available remedy

However, the High Court observed that this ground had not been raised before the trial court, leaving that court no occasion to consider it

Given the limits of its revisional jurisdiction, the High Court declined to decide the contention in the first instance and instead considered it appropriate to allow the petitioner to raise the relevant grounds through a fresh Order VII Rule 11 application

The petitioner was permitted to file a fresh application under Order VII Rule 11 CPC, which the trial court must consider in light of *Dilip Mehta v. Rakesh Gupta & Ors.*

The Court did not itself hold that the plaint was barred or order its rejection.