Lok Adalat compromise decrees obtained by fraud are liable to be quashed under writ jurisdiction.

The petitioners (legal heirs of the original defendant No. 1, Gangaram) challenged a compromise decree passed by a Lok Adalat on February 13, 2016, in R.C.S. No. 47 of 2016

The respondent No. 1 had filed a suit for declaration and injunction regarding land bearing Gat No. 23/4/3, which the original petitioner claimed was his exclusive "Hadola Inam" property held since 1950

The Trial Court record (Rojnama) indicated that summons were ordered on January 25, 2016, but were never served

Despite the lack of service, the matter was referred to the Lok Adalat on January 29, 2016, where a compromise was recorded stating the land was ancestral property

The petitioners alleged that Gangaram—who was 76 years old, illiterate, and 82% physically disabled—was misled into providing his thumb impression on the compromise terms under the pretext of signing documents for his son’s employment

1. Whether a compromise decree passed by a Lok Adalat can be challenged through a writ petition under Articles 226 and 227 of the Constitution of India on the grounds of fraud

2. Whether the compromise decree dated February 13, 2016, was obtained by practicing fraud upon the original petitioner and the court

Section 21 of the Legal Services Authorities Act, 1987, which stipulates that a Lok Adalat award is final, binding, and deemed a civil court decree, with no appeal lying against it

The court relied on the Supreme Court precedent in State of Punjab v. Jalour Singh, which established that while Lok Adalat awards are final, they can be challenged under Article 226/227 on limited grounds such as fraud

The principle from Bhaurao Dagdu Paralkar v. State of Maharashtra, holding that "fraud vitiates all solemn acts" and "unravels everything"

The court found that the procedural trajectory of the suit evidenced bad faith.

Specifically, the Trial Court referred the matter to the Lok Adalat only four days after the suit's institution without ensuring the service of summons on the defendants

The court noted that the original petitioner's extreme physical disability (82%) and illiteracy rendered him vulnerable to misrepresentation regarding the nature of the proceedings

It further observed a stark contradiction between the long-standing revenue records, which showed the land as the petitioner's exclusive Inam property, and the compromise recitals, which claimed it was ancestral property divided in 2005

The court determined that the exclusion of the petitioner’s legal heirs as necessary parties and the haste in concluding the proceedings pointed toward a fraudulent intent to grab the property

Consequently, the court held that the foundation of the compromise was vitiated by fraud, justifying interference under writ jurisdiction

The court held that once fraud is established, the finality of a Lok Adalat award under the Legal Services Authorities Act cannot bar judicial review under Article 227

The court ordered the restoration of R.C.S. No. 47 of 2016 to the file of the Trial Court for a fresh hearing on its merits, ensuring all parties are given a fair opportunity to be heard