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Issues: (i) whether an award passed by Lok Adalat in a cheque dishonour matter is final, binding and executable as a decree; (ii) whether the executing civil court could decline execution on the ground of pecuniary jurisdiction after the parties had compromised before Lok Adalat.
Issue (i): Whether an award passed by Lok Adalat in a cheque dishonour matter is final, binding and executable as a decree.
Analysis: The compromise before Lok Adalat was entered into voluntarily by the parties in proceedings arising from a cheque dishonour complaint. Under Section 20 of the Legal Services Authorities Act, 1987, Lok Adalat can deal with such matters on compromise, and under Section 21 of the same Act every award of Lok Adalat is deemed to be a decree of a civil court and is final and binding on the parties. Once the award is passed, the unsuccessful party cannot resile from the settlement, and the decree-holder is entitled to execute the award.
Conclusion: The award was held to be final, binding and executable as a decree.
Issue (ii): Whether the executing civil court could decline execution on the ground of pecuniary jurisdiction after the parties had compromised before Lok Adalat.
Analysis: The objection to pecuniary jurisdiction was raised only after the compromise award had attained finality. The court held that no such objection was raised before the Lok Adalat, where the settlement itself was recorded within the statutory framework. Since the award operated as a decree under the Act, execution could not be defeated on the ground that the civil court's pecuniary jurisdiction was limited. Such a plea would frustrate the purpose of the settlement and the statutory scheme governing Lok Adalat awards.
Conclusion: The jurisdictional objection was rejected and execution was permitted to proceed.
Final Conclusion: The challenge to the execution order failed, and the award in favour of the decree-holder remained enforceable.
Ratio Decidendi: A Lok Adalat award passed on a lawful compromise has the force of a civil court decree, is final and binding, and may be executed notwithstanding a later objection to civil court pecuniary jurisdiction.