Lok Adalat awards cannot trigger Land Acquisition re-determination under Section 28A because the statutory court award requirement is limited.

A Lok Adalat award under the Legal Services Authorities Act, 1987 cannot be treated as an award of the court under Part III of the Land Acquisition Act, 1894 for re-determination under Section 28A. Section 28A applies only where enhanced compensation is awarded by the reference court, because "court" is a restricted definition referring to the principal civil court of original jurisdiction. The deeming fiction in Section 21 of the Legal Services Authorities Act makes a Lok Adalat award final, binding, and enforceable as a civil court decree between the parties, but it does not extend to third-party landholders seeking Section 28A benefit. Lok Adalat awards arise from compromise and conciliation, not adjudication.

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Issues: Whether an award passed by a Lok Adalat under the Legal Services Authorities Act, 1987 can be treated as an award of the court under Part III of the Land Acquisition Act, 1894 for the purpose of re-determination of compensation under Section 28A of that Act.

Analysis: Section 28A permits re-determination only where the enhanced compensation is awarded by a court under Part III of the Land Acquisition Act, and the expression "Court" is a restricted definition referring to the principal civil court of original jurisdiction. The deeming provision in Section 21 of the Legal Services Authorities Act, 1987 makes a Lok Adalat award a decree of a civil court and final and binding between the parties, but that fiction is confined to enforceability and finality inter se the parties. It cannot be extended to convert the Lok Adalat award into an award of the reference court under Part III of the Land Acquisition Act so as to benefit third-party landholders under Section 28A. The object of Section 28A is to remove inequality among landholders by enabling re-determination based on a judicial award of the reference court, whereas Lok Adalat awards arise from compromise and conciliation, not adjudication.

Conclusion: An award of Lok Adalat cannot be treated as an award of the court under Part III of the Land Acquisition Act, 1894 for invoking Section 28A; the petitioners had no entitlement to re-determination on that basis.

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