Lok Adalat awards may be challenged only under Articles 226 or 227 on limited grounds.

The applicants, legal heirs of the deceased, sought enhancement of a Motor Accidents Claims Tribunal award of ₹4,10,000.

Their appeal was referred to a Lok Adalat, which recorded a settlement enhancing the award by ₹40,000.

The applicants later alleged that they had intended to settle for a substantially higher amount and had not consented to the recorded settlement.

After their attempt to challenge the award by a civil revision petition was not numbered, the matter was placed before the Court as a review application under Order 47 Rule 1 read with Section 114 CPC.

The Court considered the review application only as a challenge to the Lok Adalat award’s maintainability; it did not determine whether the applicants had, in fact, consented to the settlement.

1. Whether a review petition under Order 47 Rule 1 read with Section 114 CPC is maintainable to challenge a Lok Adalat award.

2. Whether a challenge to a Lok Adalat award may instead be pursued before the High Court under Articles 226 or 227 of the Constitution, and on what grounds.

Section 21(1) of the Legal Services Authorities Act provides that a Lok Adalat award is deemed to be a decree of a civil court or an order of the relevant court and is final and binding.

Relying on Dilip Mehta v. Rakesh Gupta, 2025 SCC OnLine SC 2737, and the principles stated in State of Punjab v. Jalour Singh and Bhargavi Constructions v. Kothakapu Muthyam Reddy, the Court held that no appeal lies against a Lok Adalat award and that a challenge may be brought before the High Court under Articles 226 or 227, on limited grounds such as lack of consent, jurisdictional error, or fraud.

The applicants’ allegation that the settlement was not properly consented to raised a ground that may be advanced in a constitutional challenge to the Lok Adalat award.

However, the application before the Court was a review petition, not a proceeding under Articles 226 or 227.

Applying the statutory finality of Lok Adalat awards and the cited Supreme Court authorities, the Court held that the review application was not the maintainable means of challenging the award.

It did not adjudicate the alleged absence of consent on its merits.

It left the applicants at liberty to pursue any remedy available to them in law, if so advised, and made no order as to costs.