The High Court of Andhra Pradesh, comprising a Division Bench of Justice Ravi Nath Tilhari and Justice Purushottam Kumar Chintalapudi, has held that an award passed by a Lok Adalat under the provisions of the Legal Services Authorities Act, 1987 is binding strictly on the parties to the settlement and cannot be challenged by third parties or strangers to the proceedings. Dismissing a writ petition filed by two individuals seeking to set aside a Lok Adalat award on grounds of fraud, misrepresentation, and collusion, the Court clarified that third parties lack locus standi to challenge such awards and that their rights in independent civil proceedings remain unaffected.
Background of the Case
The matter originated from a civil suit, O.S. No. 145 of 2023, filed by K. Vemanarayana (Respondent No. 2) against A. Sukanthi (Respondent No. 3) before the Junior Civil Judge Court, Thamballapalle, Chittoor District, seeking specific performance of an agreement of sale dated March 7, 2020. The suit was subsequently referred to and disposed of before the Lok Adalat Bench at Thamballapalle vide Lok Adalat Award No. 36 of 2023 on September 9, 2023.
Petitioners K. N. Balananda Reddy and Govindu Bhaskar Reddy filed a writ petition under Article 226 of the Constitution of India seeking a Writ of Certiorari to call for the records and set aside the Lok Adalat award. The petitioners submitted that they had previously instituted O.S. No. 43 of 2022 on the file of the Principal Senior Civil Judge, Madanapalle, seeking specific performance of an agreement of sale dated August 27, 2018 in respect of the exact same property. Furthermore, Respondent No. 3 had filed O.S. No. 70 of 2021 before the Senior Civil Judge, Madanapalle, seeking a declaration of title over the same schedule property, in which Petitioner No. 2 was arrayed as Defendant No. 11. The petitioners contended that because the property in all these suits was identical, the Lok Adalat award would adversely affect their rights and interests.
Arguments of the Parties
Advocate T. V. Jaggi Reddy, appearing for the petitioners, submitted that although the petitioners were not parties to O.S. No. 145 of 2023 or the Lok Adalat proceedings resulting in the impugned award, the compromise recorded between the second and third respondents directly impacted the petitioners’ rights in the two pending civil suits concerning the same property.
Conversely, Advocate K. Lakshmi Narayana Reddy, appearing for the Lok Adalat Bench (Respondent No. 1), argued that the petitioners were neither parties to the original suit nor to the Lok Adalat award. He submitted that strangers have no locus standi to challenge a Lok Adalat award, as the award is binding only on the parties to the settlement and their legal representatives. To support his contention, he relied on the Division Bench ruling in Vadiga Amose v. Vadiga Anjineyulu and Others.
Court’s Analysis
After perusing the material on record and evaluating the submissions, the High Court noted that the petitioners were admittedly non-parties to O.S. No. 145 of 2023 as well as the Lok Adalat award dated September 9, 2023. The Bench emphasized that under the Legal Services Authorities Act, 1987, the law is well settled that an award passed by a Lok Adalat is binding only on the parties to it and cannot bind third parties.
Citing the precedent in Vadiga Amose v. Vadiga Anjineyulu and Others, which referred to the earlier Division Bench decision in Sri Durga Malleswara Educational Society (Regd), Vijayawada v. DLSA (Lok Adalat), the Court reproduced the governing legal principle verbatim:
“the award passed in a Lok Adalat can be challenged by way of writ petition under Article 226 or Article 227 of the Constitution of India only by parties to the settlement and not by any one else, on a very limited ground such as passing of award without settlement or that settlement or compromise itself is vitiated by fraud or misrepresentation.“
Addressing the petitioners’ concern that the impugned Lok Adalat award might prejudice their claims in the pending litigation, the High Court observed that such an apprehension was misconceived. The Bench stated that since the petitioners were not parties to the Lok Adalat award, they could not be bound by it unless they were claiming rights through or as legal representatives of the parties to the award. The Court noted that this aspect can be evaluated in the pending suits, which shall be adjudicated independently in accordance with law.
Decision of the Court
Holding that the writ petition was not maintainable at the instance of the petitioners who were strangers to the Lok Adalat award, the High Court dismissed the writ petition. The Bench made no order as to costs and directed that any pending miscellaneous petitions be closed.
Case Details
Case Title: K. N. Balananda Reddy and another v. The Lok Adalat Bench at Thamballapalle and others
Case No.: Writ Petition No. 21216 of 2026
Bench: Justice Ravi Nath Tilhari and Justice Purushottam Kumar Chintalapudi
Date: July 30, 2026
