Patna High Court

Permanent Lok Adalats Empowered to Adjudicate Compoundable Traffic Challan Cases Beyond Public Utility Services.

Rani @ Rani Tiwari vs The State of Bihar

Patna High CourtJUDGMENT: June 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner filed a writ application concerning the massive pendency of traffic challans and e-challans in the State of Bihar.

Source reference: no citation

The State Government, following court directions, notified the "One Time Traffic Challan Settlement Scheme, 2026" via Notification No. 3261 dated 30.04.2026, which reduced compoundable traffic fines by approximately 50%.

Source reference: para. 3 5

While approximately 36,722 cases were disposed of in a single National Lok Adalat on 09.05.2026, a question arose regarding whether Permanent Lok Adalats could exercise jurisdiction over these cases on a regular basis to further reduce pendency.

Source reference: para. 5 6
02

Issues

1. Whether Permanent Lok Adalats established under the Legal Services Authorities Act, 1987, have the jurisdiction to adjudicate compoundable traffic challan cases.

Source reference: para. 7 9

2. Whether the definition of "Public Utility Services" under Section 22-A acts as a bar to Permanent Lok Adalats entertaining traffic offence matters.

Source reference: para. 6 9
03

Law Applied

Section 22-A of the Legal Services Authorities Act, 1987, which defines "public utility services" to include transport services.

Source reference: para. 6

Section 22-C, which sets the jurisdictional limits for Permanent Lok Adalats, prohibiting the forum from entertaining matters involving non-compoundable offences or disputes where the value exceeds Rs. 10 lakhs.

Source reference: para. 7 9

The overarching principle of "Access to Justice for All" as envisioned under Section 12 of the Act.

Source reference: para. 8
04

Reasoning

The Court analyzed the statutory limitations of the Legal Services Authorities Act and found that the Member Secretary’s apprehension—that Permanent Lok Adalats are strictly confined to public utility service disputes—was misplaced.

Source reference: para. 6-9

The Court reasoned that since traffic challans involve compoundable offences and the fines involved are significantly below the Rs. 10 lakh threshold prescribed in Section 22-C, there is no express "specific embargo" preventing these forums from taking up such cases.

Source reference: para. 9

By applying the principle of "Access to Justice," the Court determined that employing alternate dispute resolution (ADR) fora for traffic matters is necessary to expedite justice and reduce the "huge pendency" of e-challans.

Source reference: para. 8-10
05

Holding

The Court held that Permanent Lok Adalats across the State of Bihar have the jurisdiction to take up and consider compoundable traffic challan cases in addition to their existing mandate.

The Court directed that these forums shall henceforth process such matters to alleviate the burden on the judicial system. The writ petition was disposed of with these directions, while granting liberty to the intervenor to file a separate PIL regarding the causes of traffic challan pendency.

Source reference: para. 10, 11-12
Patna High Court

Original Court PDF

Rani @ Rani TiwarivsThe State of Bihar

Patna High Court · June 23, 2026

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