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Issues: Whether a civil suit seeking to declare a Lok Adalat award null and void on allegations of fraud or misrepresentation is barred by law under Order VII Rule 11(d) of the Code of Civil Procedure, 1908, and whether the only remedy is a writ petition under Articles 226 and 227 of the Constitution of India.
Analysis: An award of Lok Adalat passed on the basis of a compromise under Section 21 of the Legal Services Authorities Act, 1987 attains finality and is binding on the parties. The expression "barred by any law" in Order VII Rule 11(d) is wide enough to include binding judicial precedent, and the law declared by the Supreme Court under Article 141 is part of the legal bar. The earlier binding decision had already held that a challenge to such an award lies only by way of writ jurisdiction under Articles 226 and 227, and only on limited grounds. A civil suit to question the award, even when fraud is alleged, is therefore not maintainable.
Conclusion: The civil suit was barred by law, the plaint was liable to rejection under Order VII Rule 11(d), and the proper remedy lay in a writ petition under Articles 226 and 227.
Ratio Decidendi: A civil suit cannot be maintained to challenge a Lok Adalat award passed on compromise; such challenge lies only in writ jurisdiction under Articles 226 and 227 on limited grounds, and the term "barred by any law" in Order VII Rule 11(d) includes binding judicial precedent.