Lok Adalats lack adjudicatory jurisdiction to permit withdrawal of prosecution under Section 321 CrPC.

The petitioner (complainant) lodged an FIR against respondent Nos. 2 to 4 for several offences under the Indian Penal Code, including Sections 323, 294, 506-B, 452, and 427/34

During the trial, the Public Prosecutor moved an application under Section 321 of the Code of Criminal Procedure (CrPC) for withdrawal of prosecution

On 30.11.2013, the Judicial Magistrate First Class (JMFC), presiding in a Lok Adalat, allowed the application and acquitted the respondents

The petitioner's revision against this order was dismissed by the 6th ASJ, Rewa, on 27.06.2016

The petitioner subsequently filed this Writ Petition under Article 226 of the Constitution of India, contending that the Lok Adalat lacked jurisdiction to adjudicate on such an application and that the complainant's objections were ignored

1. Whether a Lok Adalat possesses the adjudicatory jurisdiction to allow an application for withdrawal of prosecution under Section 321 of the CrPC

2. Whether the order allowing withdrawal of prosecution was vitiated by non-application of mind and failure to consider the objections of the complainant

The court primarily applied Section 321 of the CrPC, which mandates that withdrawal from prosecution requires the Public Prosecutor's independent application of mind and the court's non-mechanical consent in the interest of justice

State of Punjab v. Jalour Singh (2008) 2 SCC 660, which held that Lok Adalats have no adjudicatory or judicial functions and are restricted purely to conciliation and the recording of compromises between parties

The court also referenced Section 21 of the Legal Services Authorities Act regarding the functions of Lok Adalats

The court reasoned that the JMFC’s order in the Lok Adalat failed to satisfy the requirements of Section 321 CrPC, as it contained no discussion on how the withdrawal served the interest of justice and entirely ignored the complainant's objections

Although a complainant’s consent is not mandatory under Section 321, their contentions are relevant factors that the court must consider

Applying the principles from Jalour Singh, the court observed that Lok Adalats are limited to administrative acts of incorporating settlements and cannot "hear" or "adjudicate" cases

By closing the criminal case via a Section 321 application, the Lok Adalat exercised a final adjudicatory function, which is beyond its legal competence

The High Court found that the lower courts erred in law by treating the Lok Adalat's order as a valid judicial determination

The court held that the Lok Adalat acted beyond its jurisdiction by adjudicating the withdrawal of prosecution

The matter was remitted to the JMFC to decide the Section 321 CrPC application afresh on its merits, in accordance with the law and after considering the complainant's objections

The petition was disposed of accordingly