Lok Adalat Awards Without Signatures Of All Rival Claimants Are Invalid, Order I Rule 8 CPC Inapplicable: Supreme Court

"A representative suit under Order I Rule 8 presupposes a community of interest among the persons represented... It would be wholly inappropriate to a proceeding where the subject matter of the dispute is the bone of contention between the claimants themselves and they are not the 'two parties' arriving at a settlement." Supreme Court, in a significant ruling delivered on August 19, 2026, held that principles governing representative suits under Order I Rule 8 of the Code of Civil Procedure, 1908 (CPC) cannot be imported into Lok Adalat proceedings where competing claimants raise rival and adverse titles to compensation.

A bench comprising Justice J.B. Pardiwala and Justice Manoj Misra observed that invoking class action principles to bind non-consenting rival disputants to a Lok Adalat award fundamentally undermines the statutory scheme of dispute resolution under the Land Acquisition Act, 1894.

The dispute arose after land measuring 489.04 guntas was acquired for the mining operations of Singareni Collieries Company Limited, leading to a reference under Sections 30 and 31 of the Land Acquisition Act, 1894 before the Principal District Judge, Khammam due to title disputes among multiple claimants. While writ proceedings challenging the acquisition were pending, the High Court referred the matter to the Lok Adalat, which subsequently passed sixteen awards based on an 'enjoyment survey' without securing the consent or signatures of all rival title claimants. The High Court of Telangana dismissed the appellants' writ petition challenging these awards, erroneously treating the compromise before the Lok Adalat as a settlement in a representative class action suit under Order I Rule 8 CPC.

The primary question before the Supreme Court was whether the principles of a representative suit under Order I Rule 8 of the CPC can be applied to sustain Lok Adalat awards where rival claimants contest entitlement to compensation. The Court was also called upon to determine whether a Lok Adalat can adjudicate disputed questions of title based on an enjoyment survey in the absence of concurrence and signatures of all interested claimants.

Order I Rule 8 CPC Inapplicable When Claimants Harbor Conflicting Interests

The Supreme Court firmly rejected the respondents' contention that Lok Adalat awards could be treated as a binding settlement in a class action suit under Order I Rule 8 of the CPC. The bench emphasized that the essential condition precedent for invoking representative proceedings is an undeniable community of interest and a shared grievance among all individuals represented.

The judges observed that applying class action principles to rival claimants completely mischaracterizes an adverse title dispute as a collective common interest. The Court noted that in land compensation disputes involving competing titles, there is no shared adversary against whom a unified class stands, but rather a direct conflict among the claimants themselves.

Treating Rival Claimants As A Single Class Destroys Section 30 Reference Scheme

"To Treat Rival Claims As A Single Class Is To Elide The Very Dispute"

The bench underscored that applying representative principles when title is the core bone of contention compounds legal infirmities rather than curing them. The Court observed that treating such rival disputants as a monolithic class eliminates the very conflict that a statutory reference under Section 30 of the Land Acquisition Act, 1894 is meant to resolve.

The Court held that an agreement under Section 29 of the Land Acquisition Act, 1894 strictly necessitates the concurrence of all interested parties, meaning a partial or truncated consensus excluding certain claimants cannot be elevated to the status of a valid statutory settlement. The bench cited the ruling in Sharda Devi v. State of Bihar to reiterate that apportionment particulars are conclusive only between parties who express mutual agreement.

"Once an award is passed by the Collector and the dispute between the claimants is the focus in a reference under Section 30 of the Act, 1894, the acquiring body leaves the pitch, and the match thereafter is between the rival claimants/persons interested."

Lok Adalat Cannot Determine Title Based On Physical Enjoyment Surveys

Turning to the nature of Lok Adalat proceedings, the Supreme Court ruled that Lok Adalats have no jurisdiction to adjudicate disputed questions of title under the guise of an enjoyment survey. The Court emphasized that an enjoyment survey captures mere physical occupation at a given moment and cannot establish lawful title or legal right to receive compensation.

The bench relied on its prior ruling in State of Punjab v. Jalour Singh and decisions of the High Court in Gudala Pentamma v. State of Telangana and Kottamula Mallaiah v. State of Telangana, reinforcing that public funds cannot be disbursed based on innovative administrative mechanisms unknown to law. The Court stressed that whenever a contest over title emerges, the Collector or reference court cannot rely on possession alone to bypass judicial adjudication.

Non-Signatories Cannot Be Bound By Lok Adalat Awards

The bench highlighted Regulation 13(6) and Regulation 17(2) of the National Legal Services Authority (Lok Adalat) Regulations, 2009, which mandate that every Lok Adalat award must bear the signatures of the parties to the compromise. The Court observed that since the appellants were neither parties to the compromise nor signatories to the awards, the settlements could not legally bind them.

Relying on the precedent in Vasant Nanaji Patre v. Vidarbha Irrigation Development Corporation, the bench reiterated that an award passed by the Lok Adalat remains strictly binding only on those parties who affirmatively enter into and execute the compromise.

Setting aside the impugned judgment of the Telangana High Court, the Supreme Court remitted the reference back to the Principal District Judge, Khammam, directing a fresh de novo hearing on merits under Section 30 of the Land Acquisition Act, 1894 within six months after issuing due notice to all concerned parties.

Date of Decision: August 19, 2026