Lok Adalat Cannot Incorporate Findings Beyond the Terms of Express Consent or Mutual Compromise

The Petitioner No. 1 (wife) initiated maintenance proceedings under Section 125 CrPC (MJC R No. 144/2020), resulting in an interim maintenance award on 17.08.2022.

Due to non-compliance, recovery proceedings under Section 125(3) CrPC were initiated. During these proceedings, the respondent made certain payments toward arrears, and the matter was referred to the National Lok Adalat.

On 14.12.2024, the Lok Adalat passed an order (Annexure P/6) which the petitioners alleged contained unauthorized findings regarding the dissolution of marriage and final settlement of all future claims.

The petitioners challenged this order via a writ of certiorari, arguing it exceeded the scope of the actual compromise, citing subsequent judicial developments such as a decree for restitution of conjugal rights in favor of the wife.

1. Whether a Lok Adalat has the jurisdiction to record findings on substantive rights, such as the dissolution of marriage, in the absence of express consent or a mutual agreement between the parties?

2. Whether an order passed by a Lok Adalat that travels beyond the terms of the compromise is sustainable under judicial review?

State of Punjab v. Jalour Singh (2008) 2 SCC 660, which establishes that a Lok Adalat does not possess adjudicatory powers and must base its awards strictly on lawful compromises or settlements arrived at by the parties.

Article 226 of the Constitution of India concerning the power of judicial review over jurisdictional errors and violations of the principles of natural justice.

The Court observed that the foundation of a Lok Adalat order is mutual consent. Upon perusal of the record (Annexure P/4), the Court found that the parties had only intended to settle specific maintenance arrears.

The Lok Adalat's order incorrectly incorporated recitals suggesting a comprehensive settlement and dissolution of marriage, which were neither pleaded nor agreed upon.

The Court reasoned that by incorporating findings that affected substantive rights without express consent, the Lok Adalat committed a jurisdictional error and violated the principles of natural justice.

The Court rejected the respondent's argument that subsequent final maintenance orders rendered the petition infructuous, noting that an inherently illegal or extra-jurisdictional order cannot be sustained simply due to later developments, especially when it could prejudice the petitioners in pending recovery or revision proceedings.

The Court set aside the impugned order dated 14.12.2024 to the extent that it recorded findings or observations beyond the actual settlement of maintenance arrears.

The Court directed that all pending and future proceedings, including those under Section 125 CrPC and recovery proceedings under Section 144(2) BNSS, must be decided independently without being influenced by the extraneous observations in the quashed Lok Adalat order.