December 20, 2025 : The Kerala State Consumer Disputes Redressal Commission, Thiruvananthapuram, has ruled that a dispute settled through a Lok Adalat award cannot be reopened by filing a fresh consumer complaint merely to enforce that settlement. The State Commission allowed a revision petition filed by Gurudeva Trust, set aside the order of the District Consumer Disputes Redressal Commission, Alappuzha, and dismissed the consumer complaint as not maintainable.
The revision petition was decided by a Bench comprising Justice B. Sudheendra Kumar, President, along with Judicial Member D. Ajith Kumar and Member K.R. Radhakrishnan.
The case arose from a deposit of ₹4.20 lakh made by the complainant, Jayaprakash, with Gurudeva Trust. When the amount was allegedly not refunded with interest on demand, Jayaprakash approached the District Legal Services Authority. The dispute was settled before a Lok Adalat, which passed an award directing the opposite parties to pay ₹4.20 lakh within six months, failing which the amount would carry interest at six percent per annum.
As the directions in the Lok Adalat award were not complied with, the complainant moved the District Consumer Commission, Alappuzha, alleging deficiency in service due to non-payment of the settled amount. The opposite parties challenged the maintainability of the complaint, arguing that the dispute had already been conclusively settled by the Lok Adalat. The District Commission rejected this objection, prompting Gurudeva Trust to file a revision petition before the State Commission.
Allowing the revision, the State Commission held that Section 21 of the Legal Services Authorities Act, 1987, makes it clear that a Lok Adalat award is final and binding on the parties and is deemed to be a decree of a civil court, executable as such. The Commission relied on the Supreme Court’s decision in Dilip Mehta v. Rakesh Gupta to reiterate that no appeal lies against a Lok Adalat award and that any challenge to such an award can only be made before the High Court under Articles 226 or 227 of the Constitution on limited grounds such as lack of consent, jurisdictional error, or fraud.
The Commission noted that the consumer complaint itself admitted that it was filed solely because the Lok Adalat award was not complied with. In such circumstances, the proper remedy available to the complainant was to seek execution of the award in accordance with law, not to initiate fresh consumer proceedings.
Rejecting the argument based on Section 100 of the Consumer Protection Act, 2019, the State Commission clarified that the provision applies only when a dispute continues to exist. Once a dispute is settled through a Lok Adalat award, it ceases to exist and cannot be revived by invoking consumer jurisdiction. The presence of additional opposite parties, the Commission held, would not change this position when the entire dispute had already been settled.
Holding that the District Commission had committed illegality, impropriety, and incorrectness in entertaining the complaint, the State Commission allowed the revision petition, set aside the impugned order, and dismissed the consumer complaint as not maintainable. 1768487198_jayaprakash-646945
Cause Title: Gurudeva Trust v. Jayaprakash
Case No.: Revision Petition No. 56 of 2024
Coram: Justice B. Sudheendra Kumar (President), D. Ajith Kumar (Judicial Member), K.R. Radhakrishnan (Member)
