Res judicata does not bar writ petitions seeking enforcement of Lok Adalat awards against State authorities.

The Appellants, formerly daily-rated employees, filed W.P.(S) No. 1298 of 2023 seeking pensionary benefits by counting their service from the date of initial appointment rather than regularization

The matter was referred to the National Lok Adalat, which passed an award on 13.07.2024 based on a settlement where the Executive Engineer undertook to pay the differential benefits

Following the State’s failure to implement the award, the Appellants filed a contempt petition, which was dropped on 07.11.2025 as the award was held not amenable to contempt jurisdiction

Subsequently, the Appellants filed W.P.(S) No. 6739 of 2025 for enforcement of the award. A Single Judge dismissed this petition on 26.11.2025, holding it barred by res judicata and observing that a Writ Court should not act as an executing court

The Appellants challenged this dismissal through the present Letters Patent Appeal (LPA).

1. Whether a subsequent writ petition seeking enforcement of a National Lok Adalat award is barred by the principle of res judicata

2. Whether the High Court, under Article 226 of the Constitution, can direct the implementation of a Lok Adalat award when State authorities fail to honor their undertaking

The Court applied Section 21 of the Legal Services Authorities Act, 1987, which provides that every award of a Lok Adalat shall be deemed a decree of a civil court and shall be final and binding on all parties

It relied on the precedent of State of Punjab v. Jalour Singh (2008) 2 SCC 660, which established that a Lok Adalat award is final and executable as a decree, and any challenge to it can only be made under Article 226/227 on extremely limited grounds

Furthermore, the Court emphasized the State's obligation to act fairly and reasonably under Articles 14 and 21 of the Constitution of India

The Court held that the principle of res judicata was inapplicable because the earlier writ petition was disposed of via settlement in a Lok Adalat, not through an adjudication on merits by a court

The non-implementation of the award gave rise to a fresh and continuing cause of action

The Division Bench criticized the Single Judge’s refusal to exercise jurisdiction, noting that while an award is executable as a civil decree, the High Court is not precluded from issuing directions under Article 226 to prevent the State from arbitrarily defying its own statutory undertakings

The Court observed that the Appellants were elderly individuals suffering due to the "indifferent and whimsical attitude" of the State

Since the State failed to challenge the award or provide a cogent reason for non-compliance, technical objections regarding maintainability could not be allowed to defeat the interests of justice

It held that the writ petition was maintainable to enforce the statutory settlement reached in the Lok Adalat

The Court directed the Respondents to implement the award dated 13.07.2024 within four weeks

Additionally, due to the deliberate delay by the State, the Court ordered the payment of 6% interest per annum on the due amounts, calculated from the date of the Lok Adalat award until the actual date of payment