Lok Adalat award can support re-determination of compensation under land acquisition law when filed within time.

Section 28A of the Land Acquisition Act permits re-determination of compensation where a court award grants higher compensation than the Collector's award. A Lok Adalat award is deemed to be a civil court decree under Section 21 of the Legal Services Authorities Act, 1987, and is final and binding; its status is reinforced by the Lok Adalat's civil court powers under Section 22. On that footing, a Lok Adalat award in a reference case can serve as the for a Section 28A claim, provided it is made within time. The claim for re-determination was therefore maintainable, and the rejection orders were unsustainable.

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Issues: Whether compensation under Section 28A of the Land Acquisition Act, 1894 can be re-determined on the basis of an award passed by a Lok Adalat.

Analysis: Section 28A confers a right to seek re-determination where the Court awards compensation in excess of the Collector's award. A Lok Adalat award, under Section 21 of the Legal Services Authorities Act, 1987, is deemed to be a decree of a civil court and is final and binding. Section 22 further equips the Lok Adalat with civil court powers. An award passed by the Lok Adalat in a reference case therefore stands on the same footing as a court decree, and the statutory fiction extends to such award for the purpose of Section 28A. The applications were also made within the prescribed period.

Conclusion: The claim for re-determination under Section 28A on the basis of the Lok Adalat award is maintainable and the rejection orders are unsustainable.

Ratio Decidendi: A Lok Adalat award, being a deemed decree of a civil court under Section 21 of the Legal Services Authorities Act, 1987, can constitute the basis for re-determination of compensation under Section 28A of the Land Acquisition Act, 1894.

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