Lok Adalat award finality bars further Section 138 prosecution; enforcement lies only through execution proceedings.

Once a dispute is settled before Lok Adalat and an award is passed under Section 21 of the Legal Services Authorities Act, 1987, the award is final, binding, and executable as a decree. The criminal court cannot ignore that settlement and continue prosecution under Section 138 of the Negotiable Instruments Act as if no compromise had been reached; it becomes functus officio on the settled dispute. The proper remedy for the successful party is execution of the Lok Adalat award before the competent forum. The conviction and revisional order were therefore set aside, and enforcement was confined to execution proceedings.

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Issues: Whether, after an award is passed by the Lok Adalat on the basis of a settlement between the parties, the Magistrate can proceed to convict the accused under Section 138 of the Negotiable Instruments Act, or whether the proper remedy is execution of the Lok Adalat award.

Analysis: An award made by the Lok Adalat under the Legal Services Authorities Act, 1987 is final and binding on all the parties and no appeal lies against it. Once the parties have consented to the settlement and the award has been signed and passed, the award operates as an executable decree. In such a situation, the criminal court cannot ignore the mandate of Section 21 and continue with the prosecution as though no settlement had been reached. The correct course for the successful party is to pursue execution of the award before the appropriate forum. The Magistrate, therefore, had no jurisdiction to convict the accused under Section 138 after the Lok Adalat award.

Conclusion: The conviction and the revisional order were unsustainable and were set aside. The respondent was left to enforce the Lok Adalat award by execution proceedings.

Final Conclusion: The revision succeeded because the Lok Adalat settlement displaced further adjudication in the criminal complaint, and the award alone remained enforceable in law.

Ratio Decidendi: Once a dispute is finally settled before the Lok Adalat and an award is passed under Section 21 of the Legal Services Authorities Act, 1987, the criminal court becomes functus officio and cannot proceed to convict under Section 138 of the Negotiable Instruments Act; enforcement lies only through execution of the award.

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