Executing Court cannot annul a Lok Adalat award for PTCL Act violations in execution proceedings.

The Petitioner (Decree Holder/DHr) filed a suit for specific performance against the Respondent (Judgment Debtor/JDr) based on an Agreement of Sale (AoS) dated 10.01.2011.

The suit culminated in a compromise decree before the Lok Adalat on 21.04.2011.

Upon the JDr's failure to execute the sale deed, the DHr filed Execution Petition No. 13/2021.

The JDr objected, contending the land was "granted land" under the Karnataka SC/ST (Prohibition of Transfer of Certain Lands) Act, 1978 (PTCL Act), and that the decree was a nullity.

On 30.08.2025, the Executing Court dismissed the execution petition, holding the decree was hit by the PTCL Act.

The Petitioner challenged this dismissal via Civil Revision Petition.

1. Whether an Executing Court has the jurisdiction to annul a Lok Adalat Award on the grounds that it violates the provisions of the PTCL Act.

The Court applied Sections 21 and 22E of the Legal Services Authorities Act, 1987, which establish that every award of a Lok Adalat is deemed a decree of a civil court, is final and binding, and no appeal lies against it.

It relied on the Supreme Court precedent in Dilip Mehta v. Rakesh Gupta (2025) and State of Punjab v. Jalour Singh, which hold that a Lok Adalat award can only be challenged via a writ petition under Article 226 or 227 of the Constitution on limited grounds like fraud or lack of consent.

The court referred to the principle that an Executing Court cannot go behind the decree or sit in judgment over the validity of a compromise recorded by a Lok Adalat.

The High Court reasoned that the Executing Court overstepped its jurisdiction by determining whether the property was "granted land" under the PTCL Act.

It noted that the determination of land status under the PTCL Act is within the exclusive purview of the authorities designated under that Act, not the Civil Court.

The Court emphasized that a Lok Adalat award is a "deemed decree" only for the purposes of execution and attains statutory finality under the Legal Services Authorities Act.

Therefore, the Executing Court's role is strictly confined to giving effect to the award; it has no authority to annul the award or treat execution objections as an alternative remedy for challenging its validity.

The court observed that the JDr had not even approached the PTCL authorities, making the Executing Court's preemptive annulment of the award perverse.

The High Court set aside the order dated 30.08.2025, restored Execution Petition No. 13/2021, and directed the lower court to proceed in accordance with the law.

It clarified that the JDr remains at liberty to invoke the jurisdiction of PTCL authorities even after the execution of the sale deed.