Unsupported fraud allegations and inordinate delay do not warrant interference with a Lok Adalat settlement.

The petitioner challenged a Lok Adalat compromise in O.S. No. 43/2009, alleging that her signatures had been obtained hurriedly and without explaining the terms, which gave her only a limited life interest in certain properties.

The Lok Adalat record showed that she was represented by counsel, that the compromise terms were read over and explained, and that she confirmed her understanding of them.

After her application under Section 151 CPC to recall the compromise was rejected on 27 May 2019, she filed this writ petition.

The compromise was recorded nearly a decade before the challenge, and the Court found the delay insufficiently explained.

The judgment contains inconsistent references to the date of the Lok Adalat decree: the prayer refers to 21 February 2009, while the body also refers to 21 February 2019.

1. Whether a challenge alleging fraud or coercion in a Lok Adalat compromise may be brought before the High Court under Article 227, rather than by an application under Order XXIII Rule 3 CPC.

2. Whether the petitioner established grounds to set aside the compromise, having regard to the Lok Adalat record and the delay in challenging it.

The Court stated that a Lok Adalat compromise award cannot be challenged before the Civil Court by invoking Order XXIII Rule 3 CPC; a party alleging that such a settlement is vitiated by fraud or coercion may invoke the High Court’s supervisory jurisdiction under Article 227 of the Constitution.

The availability of that remedy does not dispense with the need to establish the alleged vitiating circumstances or satisfactorily explain the delay.

In exercising supervisory jurisdiction, the Court should respect a settlement reached after deliberation and with counsel’s assistance, and interfere where its validity is materially affected or it results in a manifest miscarriage of justice.

The Court considered the petitioner’s Article 227 challenge but found that the contemporaneous Lok Adalat proceedings contradicted her assertion that the compromise terms were not explained: she was represented by counsel, the terms were read over and explained, and she confirmed her understanding.

Her allegation of fraud was unsupported by tangible material, and her limited interest in the allotted properties did not, by itself, establish involuntary consent.

The nearly decade-long delay was also not satisfactorily explained.

Finding no jurisdictional error warranting intervention under Article 227, it dismissed the writ petition and made no order as to costs.