Mediated settlement validity depends on free consent and substantial compliance; vague coercion claims and procedural lapses do not defeat it.

Mediated consent terms signed by the parties are not invalidated merely because a party later alleges coercion, undue influence or duress; the challenge must be supported by clear particulars and material showing that free consent was absent. Where the mediation record shows the settlement was concluded, annexures were subsequently signed, and no substantiated basis exists to invoke the Contract Act, the consent terms remain valid and binding. The mediation framework also requires the settlement to be reduced to writing, signed and forwarded for the Tribunal's consideration, but the timing requirements for the Tribunal's order are treated as directory. Substantial compliance is sufficient, and procedural lapse without legal prejudice does not render the settlement unenforceable.

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Issues: (i) Whether the consent terms executed during mediation were vitiated and liable to be set aside on the grounds of coercion, undue influence and duress under the Indian Contract Act, 1872. (ii) Whether the alleged non-compliance with the mediation rules, including forwarding and recording of the settlement, rendered the consent terms unenforceable.

Issue (i): Whether the consent terms executed during mediation were vitiated and liable to be set aside on the grounds of coercion, undue influence and duress under the Indian Contract Act, 1872.

Analysis: The consent terms were admittedly signed by the parties. The challenge was confined to the absence of finality in two annexures and to allegations of pressure, coercion and undue influence. The record showed that the mediator's reports treated the settlement as concluded, that the annexures were later signed, and that the objections raised were unsupported by particulars. The allegations of coercion and undue influence were found to be vague and unsubstantiated, and no material was shown to establish that the consent was not free or that the agreement was invalid under the Contract Act.

Conclusion: The consent terms were not vitiated and were held to be valid and binding.

Issue (ii): Whether the alleged non-compliance with the mediation rules, including forwarding and recording of the settlement, rendered the consent terms unenforceable.

Analysis: Rule 25 required the settlement to be reduced to writing, signed by the parties and forwarded to the Tribunal. Rule 26 required the Tribunal to fix a hearing and, upon satisfaction, pass an order in terms of the settlement. The record showed compliance with this framework. The Tribunal's timing was held to be directory and not mandatory, and the challenge based on Rule 26 was also not part of the pleadings before the Tribunal or in the appeals. No breach sufficient to invalidate the settlement was established.

Conclusion: The mediation rules were substantially complied with and the settlement was not rendered unenforceable.

Final Conclusion: The appeals failed and the impugned order rejecting the challenges to the mediated settlement was sustained.

Ratio Decidendi: A mediated settlement duly signed by the parties will not be invalidated in the absence of clear proof that free consent was vitiated or that any procedural lapse under the mediation framework caused legal prejudice; directory time requirements do not defeat an otherwise concluded settlement.

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