Judgment Emphasizes Magistrate's Exclusive Authority in Judicial Functions, Invalidating Lok Adalat's Summoning Orders
In a significant ruling, the Allahabad High Court has quashed the proceedings initiated by a National Lok Adalat, emphasizing that Lok Adalats do not have the jurisdiction to perform judicial functions such as rejecting police final reports and treating matters as complaint cases. The judgment was delivered by Justice Achal Sachdev in the case of Smt. Mayya @ Prem Kumari v. State of U.P., highlighting the procedural missteps taken by the Lok Adalat in addressing the complaint filed against Smt. Mayya alias Prem Kumari and others.
The case originated when a protest petition was filed against a final report submitted by the police, which was subsequently treated as a complaint by a Judicial Magistrate in a Lok Adalat session. This led to a summoning order against the applicants in the complaint case. However, the High Court clarified that such judicial functions must be conducted by a magistrate in a regular court setting.
Justice Sachdev, referencing the Supreme Court's decisions, reiterated that Lok Adalats are conciliatory forums designed to facilitate settlements between parties and cannot adjudicate cases on merits or issue judicial orders if no settlement is reached. Consequently, any judicial act undertaken by the Lok Adalat, such as the registration of a complaint following the rejection of a final report, is considered jurisdictionally void and unsustainable in law.
The court underscored the procedural framework that must be adhered to when a Magistrate decides to reject a final report. This includes following the complaint case procedure under the Criminal Procedure Code, which involves recording statements, conducting inquiries, and issuing processes only when sufficient grounds exist. Such actions are beyond the scope of Lok Adalats, which must return unresolved cases to regular courts for appropriate judicial intervention.
In light of these observations, the High Court has annulled the summoning order and all subsequent proceedings arising from the Lok Adalat's jurisdictionally flawed actions. The judgment serves as a critical reminder of the distinct roles played by judicial courts and Lok Adalats, reinforcing the sanctity of procedural law and the limitations of conciliatory forums in the Indian legal system.
Bottom line:-
Lok Adalat has no jurisdiction to reject a police Final Report (FR) and register the matter as a complaint case. Such acts are judicial functions to be performed by a Magistrate in a regular court. Any subsequent proceedings, including summoning orders, arising from such jurisdictionally void acts are vitiated and unsustainable in law.
Statutory provision(s): Legal Services Authorities Act, 1987 Sections 20, 21, 22E; Criminal Procedure Code, 1973 Section 482; Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528.
Smt. Mayya @ Prem Kumari v. State of U.P., (Allahabad) : Law Finder Doc id # 2890715
