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2026 Supreme(All) 302

HIGH COURT OF JUDICATURE AT ALLAHABAD 
ABDUL SHAHID, J.
Ram Gopal – Revisionist
Versus 
State Of U.P. And  Others – Opposite Party
CRIMINAL REVISION No. - 3467 of 2025
Decided On : 17-03-2026

Advocates Appeared:
For the Revisionist : Devika Kapoor, Pranjal Singh
For the Opposite Party : G.A., Pravin Kumar, Sudhir Kumar

Lok Adalat awards are to be challenged only through writ petitions under Articles 226 and 227 of the Constitution; they do not possess adjudicatory powers.

Headnote:(A) Constitution of India - Article 226 and Article 227 - Criminal Procedure Code - Section 482 - Jurisdiction of Lok Adalat - An award by Lok Adalat is akin to a civil court decree; challenging it requires a writ petition, not a criminal revision - Lok Adalats lack adjudicatory powers, functioning instead as conciliators. (Paras 4, 6, 8)

(B) Limitation - Proceeding under Sections 5 and 14 of the Limitation Act considered regarding admission of appeals after the prescribed period for sufficient cause. (Paras 7)

Facts of the case:
The revision stems from a Lok Adalat award regarding a criminal case. The award was contested unsuccessfully in the District Court.

Findings of Court:
The application under Section 482 Cr.P.C. was deemed not maintainable, affirming Lok Adalat’s role as non-adjudicatory.

Issues: The enforceability of Lok Adalat awards and the correct procedural approach to contesting these awards were questioned.

Ratio Decidendi: The court reiterated that awards made by Lok Adalats derive from consensus and lack adjudicative authority, emphasizing the need for petitions under Articles 226 and 227 for challenges.

Result: Revision dismissed as withdrawn.

Table of Content
1. challenge of lok adalat award basis (Para 2 , 3)
2. nature and limitations of lok adalat powers (Para 4 , 5 , 6 , 7)
3. dismissal with leave for other remedies (Para 8 , 9)

JUDGMENT :

ABDUL SHAHID, J.

1. Heard Sri Pranjal Singh, learned counsel for the revisionist, and Sri Sudhir Kumar, learned counsel for opposite party nos. 2 to 4.

2. The present criminal revision has been initiated on the basis of an award dated 11.12.2021 passed in the National Lok Adalat by the Chief Judicial Magistrate, Budaun, in Criminal Case No. 117 of 2019 (State of U.P. versus Sudhir Kumar and others), arising out of NCR No. 155 of 2015. The said award was challenged by way of Criminal Appeal No. 17 of 2024 (Ram Gopal versus State of U.P. and others), which was decided by the learned Additional District and Sessions Judge/Special Judge (E.C. Act), Budaun, vide order dated 15.02.2025, and the same was dismissed.

3. Thus, the genesis of the present criminal revision lies in the award dated 11.12.2021 passed by the National Lok Adalat.

4. This Court in Shashwat Agrawal Versus State of U.P. and another , 2024 : AHC : 159141, has held as under:

"7. .....The moment, the same officer, who was holding the post of Magistrate takes up the matter as a Presiding Officer of the Lok Adalat seizes the power of the Magistrate and in Lok Adalat, the Presiding Officer's role is only that of a conciliator, who can facilitate the parties to arrive at a compromise and if the parties disagreed and did not settle their dispute, then the Lok Adalat is deprived of any powers of a Magistrate to adjudicate the dispute between the parties.

8. It is settled view that even if a criminal proceeding has been referred to the Lok Adalat, the award passed by the Lok Adalat shall be treated as a decree of a civil court and a decree of civil court cannot impose any penalty.

14. As has been held by the Apex Court in Jalour Singh (supra) against an award passed by the Lok Adalat. The same can be challenged only by way of a petition under Section 226 or 227 of the Constitution of India and not otherwise and the aforesaid views have already been affirmed in Bharvagi Construction (supra)Â by the Apex Court. In view thereof, the instant application under Section 482 Cr.P.C. against the award of Lok Adalat is not maintainable. Therefore, this Court while exercising the jurisdiction under Section 482 Cr.P.C. cannot interfere with the Award passed by the Lok Adalat, which is a decree passed by civil court, and is not amenbale to the criminal jurisdiction under Section 482 Cr.P.C."

5. In the State of Punjab and another vs. Jalour Singh and others , AIR 2008 (2) SCC 660, three Judges Bench of the Apex Court has held as under:

"8. It is evident from the said provisions that Lok Adalats have no adjudicatory or judicial functions. Their functions relate purely to conciliation. A Lok Adalat determines a reference on the basis of a compromise or settlement between the parties at its instance, and put its seal of confirmation by making an award in terms of the compromise or settlement. When the Lok Adalat is not able to arrive at a settlement or compromise, no award is made and the case record is returned to the court from which the reference was received, for disposal in accordance with law. No Lok Adalat has the power to "hear" parties to adjudicate cases as a court does. It discusses the subject matter with the parties and persuades them to arrive at a just settlement. In their conciliatory role, the Lok Adalats are guided by principles of justice, equity, fair play.When the LSA Act refers to 'determination' by the Lok Adalat and 'award' by the Lok Adalat, the said Act does not contemplate nor require an adjudicatory judicial determination, but a non-adjudicatory determination based on a compromise or settlement, arrived at by the parties, with guidance and assistance from the Lok Adalat. The 'award' of the Lok Adalat does not mean any independent verdict or opinion arrived at by any decisi

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