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Issues: Whether an award passed by a Lok Adalat under Section 20 of the Legal Services Authorities Act, 1987 can serve as the basis for redetermination of compensation under Section 28A of the Land Acquisition Act, 1894.
Analysis: The Lok Adalat under the 1987 Act is meant to facilitate compromise or settlement and does not exercise an adjudicatory function. Its award is the product of a non-adjudicatory settlement process, and the deeming fiction in Section 21 only gives the award enforceability as a decree; it does not convert the award into an award of the Court under Part III of the Land Acquisition Act, 1894. Section 28A applies only where compensation has been enhanced by an award of the Court after adjudication under the Land Acquisition Act, 1894, and the statutory scheme of Sections 18, 23 and 26 contemplates such adjudication. Extending the Section 21 fiction further, so as to treat a Lok Adalat award as if it were an award of the reference court for Section 28A purposes, would amount to impermissibly enlarging the fiction beyond its purpose.
Conclusion: An award passed by a Lok Adalat under Section 20 of the Legal Services Authorities Act, 1987 cannot be used to invoke Section 28A of the Land Acquisition Act, 1894.