Lok Adalat awards warrant Article 227 interference only for lack of consent, jurisdictional error, or fraud.

Mala Guleria filed proceedings under the Protection of Women from Domestic Violence Act, 2005, against her husband, Ajay Pal Singh.

The Chief Judicial Magistrate, Kangra at Dharamshala, directed the husband to pay maintenance of ₹30,000 per month from the date of filing of the complaint and restrained him from committing domestic violence.

The husband preferred an appeal under Section 29 of the DV Act before the Additional District Judge.

During the appeal, both parties appeared with counsel in a pre-Lok Adalat sitting on 24 April 2024 and made statements agreeing to modification of the maintenance amount to ₹20,000 per month.

The husband additionally agreed to pay the outstanding maintenance in three half-yearly instalments, with the first instalment payable on or before the Lok Adalat scheduled for 11 May 2024.

On the basis of those statements, the National Lok Adalat passed an award on 11 May 2024, modifying the maintenance from ₹30,000 to ₹20,000 per month.

The husband challenged the award under Article 227 of the Constitution, contending that the Lok Adalat had not recorded fresh statements on the date of the award, that the statements had been recorded during the regular appellate proceedings, and that he had agreed only to pay ₹20,000 per month from April 2024.

Whether the Lok Adalat award was liable to be set aside merely because the parties’ statements were recorded by the Appellate Court during the pre-Lok Adalat proceedings and were not recorded afresh by the Lok Adalat on 11 May 2024?

Whether the husband established any recognised ground for interference with a Lok Adalat award under Article 227 of the Constitution, such as absence of consent, jurisdictional error, fraud, or misrepresentation?

Whether the agreed reduction of maintenance to ₹20,000 per month altered the trial Court’s direction that maintenance was payable from the date of filing of the complaint?

The Court applied Article 227 of the Constitution, under which interference with a Lok Adalat award is supervisory and exceptional rather than appellate.

It relied on the Supreme Court’s decision in Dilip Mehta v. Rakesh Gupta & Others, which, following State of Punjab v. Jalour Singh and Bhargavi Constructions v. Kothakapu Muthyam Reddy, held that a Lok Adalat award based on settlement is final and binding, executable as a decree, and cannot be challenged through an ordinary appeal or civil suit; a constitutional challenge is maintainable only on limited grounds such as lack of consent, jurisdictional error, or fraud.

The Court also applied Section 29 of the Protection of Women from Domestic Violence Act, 2005, under which the husband had filed the appeal against the Magistrate’s order.

The governing principle was that a party who has voluntarily made a clear and informed statement consenting to settlement cannot subsequently avoid the resulting Lok Adalat award merely because the award was formally passed on a later date or because the settlement statements were recorded by the appellate court before the matter was placed before the Lok Adalat.

The Court found that both parties had been present with counsel when their statements were recorded on 24 April 2024, and that the husband’s statement was unequivocal: he accepted reduction of maintenance to ₹20,000 per month and undertook to pay the arrears in three half-yearly instalments.

The husband did not allege that his statement was fabricated, made without consent, or induced by fraud or misrepresentation, nor did he raise any such objection between the date of the statement and the passing of the award.

Consequently, the absence of fresh statements before the Lok Adalat on 11 May 2024 did not constitute a jurisdictional defect or invalidate the settlement-based award.

The Court further held that the parties had agreed only to reduce the quantum of maintenance; neither party had agreed to modify the trial Court’s direction that maintenance would run from the date of filing of the complaint.

Therefore, the award correctly preserved that aspect of the trial Court’s order while reducing the monthly amount to ₹20,000.

Since no limited ground warranting constitutional interference was established, the challenge failed.

The Court upheld the modification of maintenance from ₹30,000 to ₹20,000 per month, while maintaining the original direction that maintenance was payable from the date of filing of the complaint, together with the agreed arrangement for payment of arrears in instalments.

The petition was accordingly dismissed, and any pending applications were also disposed of.