Lok Adalat award validity depends on authorised compromise and strict statutory compliance; lack of authority can justify judicial review.

A Lok Adalat award is binding only when a valid reference exists, a genuine compromise is entered into by duly authorised parties, and the statutory procedure for recording and signing the award is strictly followed. Under the Legal Services Authorities Act, 1987, the Regulations, and the society's bye-laws, a secretary has no inherent power to compromise litigation without specific authorisation. On the facts noted, no resolution or other proof of lawful authority was produced, the alleged power of attorney was not established from the record, and the award was not properly signed in accordance with the governing requirements. The award was therefore treated as legally invalid and liable to be set aside under writ jurisdiction.

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Issues: Whether the Lok Adalat award was liable to be set aside on the ground that the compromise was entered into by persons not duly authorised and the award did not satisfy the statutory requirements governing Lok Adalat settlements.

Analysis: The challenge was examined in the context of Sections 19, 20, 21 and 29A of the Legal Services Authorities Act, 1987 and the Andhra Pradesh State Legal Services Authority Regulations, 1996, which require a valid reference, a genuine compromise or settlement, and due compliance in recording and signing the award. The Court also considered the society's bye-laws and the statutory position under the Andhra Pradesh Societies Registration Act, 2001, holding that a secretary has no inherent power to compromise litigation on behalf of the society unless the bye-laws or a resolution specifically authorise such action. The material showed that no special or ordinary resolution authorising compromise was produced, the petitioner was not treated as duly empowered on the date of the award, the alleged general power of attorney of the other side was not proved from the record, and the award was not signed by all members of the Lok Adalat bench or by properly authorised parties. The Court further held that although fraud can vitiate a proceeding, such allegation must be established by material before the competent forum, and in the present case the decisive infirmity was the absence of lawful authority and procedural compliance, not merely the allegation of fraud. The writ jurisdiction under Article 226 of the Constitution of India was therefore available to test the validity of the award.

Conclusion: The Lok Adalat award was not a valid award in law and was liable to be set aside.

Final Conclusion: The writ petition succeeded and the impugned Lok Adalat award stood annulled for non-compliance with the governing statutory and authorisation requirements.

Ratio Decidendi: A Lok Adalat award is final and binding only when a compromise is arrived at by duly authorised parties and the statutory procedure for recording and signing the award is strictly complied with; absence of such authority or compliance renders the award vulnerable to judicial review and setting aside.

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