Bhakti Vinaykumar Khatu & Anr. v. Jayanti Bhaskar Shirsat - Lok Adalat Award
National Legal Services Authority (Lok Adalat) Regulations 2009 - Regulation 12 - The Award passed by the Lok Adalat can only be challenged on the ground mentioned under the Regulation 12(3) of the National Legal Services Authority (Lok Adalat) Regulations 2009. (Para 13)
Case Info
Case Information
Case name: Bhakti Vinaykumar Khatu & Anr. v. Jayanti Bhaskar Shirsat & Anr.
Neutral citation: Not mentioned in the extracted text (only “CIVIL APPEAL Nos. OF 2026 (arising out of SLP(C) Nos. 13941-13942/2024)” appears, without a neutral citation number).
Coram:Hon’ble Mr. Justice Prashant Kumar MishraHon’ble Mr. Justice Vipul M. Pancholi
Judgment date: 28 January 2026 (New Delhi)
Statutes / laws referred
The judgment refers to and applies:
- Legal Services Authorities Act, 1987 – especially Section 20 (procedure for reference and conduct before Lok Adalat).
- National Legal Services Authority (Lok Adalat) Regulations, 2009 – Regulation 12(3) (mode and ground of challenge to an award based on settlement in a Lok Adalat).
- Constitution of India – Articles 226 and 227 (writ and supervisory jurisdiction of High Courts).
Brief summary
The appellants, daughters of the first respondent and sisters of the second respondent, challenged a Lok Adalat compromise decree in a partition suit, alleging that their brother/attorney exceeded his authority and committed fraud in reducing their shares, and that Section 20 of the Legal Services Authorities Act, 1987 was violated. The Supreme Court upheld the Bombay High Court’s dismissal of their writ petitions, holding that the power of attorney expressly empowered the brother to compromise disputes including family partition, that the Lok Adalat had followed the procedure under Section 20 after the High Court verified the records, and that an award based on settlement can only be challenged on that limited procedural ground under Regulation 12(3) of the 2009 Regulations. The Court further noted that the appellants had acted on the compromise by accepting rent from tenants of the properties falling to their share and were therefore estopped from challenging the Lok Adalat award, leading to dismissal of the appeals.