Permanent Lok Adalat has no Jurisdiction Over Service Matters

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15-Sep-2026

Legal Services Authorities Act, 1987

State of Rajasthan v. Bhanwar Lal Jain

"The words 'any party to a dispute' under Section 22-C of the Act of 1987 must be interpreted in the context of the jurisdiction for which the Permanent Lok Adalat has been established."

Justice Anoop Kumar Dhand

Rajasthan High Court

Why in News?

Justice Anoop Kumar Dhand, in State of Rajasthan v. Bhanwar Lal Jain (2026), set aside an award passed by the Permanent Lok Adalat (PLA), Merta, Nagaur, holding that the PLA lacked jurisdiction to adjudicate a dispute concerning grant of service benefits, as such a dispute did not fall within the meaning of "public utility services" under Section 22A(b) of the Legal Services Authorities Act, 1987.

What was the Background of State of Rajasthan v. Bhanwar Lal Jain (2026) Case?

The respondent was appointed as a Helper on a temporary basis in 1978, and was declared a semi-permanent employee in 1980.
However, for the purpose of all service benefits, his services were counted only from September 1981.
Aggrieved, the respondent approached the Permanent Lok Adalat, Merta, Nagaur, seeking service benefits from the initial date of his appointment.
The PLA allowed the application and decided the matter in the respondent's favour, directing the Public Health Engineering Department to grant service benefits from 1978.
The petitioner-department challenged the maintainability of the application before the Rajasthan High Court, contending that since the issue related to grant of service benefits, it could not have been adjudicated by the PLA.

What were the Court's Observations?

On the Limited Jurisdiction of the Permanent Lok Adalat:
The Court observed that the purpose of establishing a Permanent Lok Adalat is to exercise limited jurisdiction over one or more public utility services, and not otherwise.
On the Scope of "Public Utility Services" under Section 22A(b):
The Court noted that the categories of public utility services have been specifically enumerated under the Act, with power vested in the Central or State Government to expand the definition to include any other service, indicating a deliberately confined jurisdiction.
On the Interpretation of "Any Party to a Dispute" under Section 22C:
The Court held that this phrase must be read in the context of the jurisdiction for which the Permanent Lok Adalat has been established, and cannot be read to extend the PLA's authority beyond public utility service disputes.
On Service Benefit Disputes Falling Outside PLA's Purview:
The Court held that since the matter pertained to grant of service benefits to the respondent, it did not fall under the purview of "public utility services" as defined under Section 22A(b), and the PLA had therefore exercised power not vested in it.
In view of the above, the Court quashed the award passed by the PLA, granting the respondent liberty to file a representation before the petitioner-department, which was directed to hear and decide the matter sympathetically and expeditiously, preferably within two months.

What are Permanent Lok Adalats?

About Lok Adalats:

Introduction	The term Lok Adalat means People’s Court. It is based on Gandhian principles. As per the Supreme Court it is an old form of adjudicating system prevailed in ancient India. It is one of the components of the Alternative Dispute Resolution (ADR) system. It delivers informal, cheap and expeditious justice to the common people.
First Lok Adalat	The first Lok Adalat camp was organized in Gujarat in 1982 as a voluntary and conciliatory agency without any statutory backing
Statutory Recognition	It was given statutory status under the Legal Services Authorities Act, 1987. The Act makes the provisions relating to the organization and functioning of the Lok Adalats.
Organization	The National Legal Services Authority (NALSA) along with other Legal Services Institutions deal with the organization of Lok Adalats. NALSA was constituted under the Legal Services Authorities Act, 1987 which came into force on 9th November 1995.
Composition	Generally, a Lok Adalat consists of a judicial officer as the chairman and a lawyer (advocate) and a social worker as members.
Jurisdiction	A Lok Adalat shall have jurisdiction to determine and to arrive at a compromise or settlement between the parties to a dispute in respect of: Any case pending before any court. Any matter which is falling within the jurisdiction of any court and is not brought before such court. Any case pending before the court can be referred to the Lok Adalat for settlement if the parties agree to settle the dispute in the Lok Adalat.
Proceedings	All proceedings before a Lok Adalat shall be deemed to be judicial proceedings within the meaning of the Indian Penal Code, 1860 (IPC) and every Lok Adalat shall be deemed to be a Civil Court for the purpose of the Code of Civil Procedure, 1908 (CPC).
Awards	The award by the Lok Adalat is binding on the parties and it has the status of a decree of a civil court, and it is non-appealable, which does not cause the delay in the settlement of disputes finally.
Benefits	There is no court fee and if the court fee is already paid the amount will be refunded if the dispute is settled at Lok Adalat. There is procedural flexibility and speedy trial of the disputes.

Permanent Lok Adalats:

About:

The Legal Services Authorities Act, 1987 was amended in 2002 to provide for the establishment of the Permanent Lok Adalats to deal with cases pertaining to the public utility services like transport, postal, telegraph etc.

Essential Features:

These have been set up as permanent bodies under Section 22-B of the Legal Services Authorities Act, 1987.
It shall consist of a Chairman who is or has been a district judge or additional district judge or has held judicial office higher in rank than that of the district judge and two other persons having adequate experience in public utility services.
It shall not have jurisdiction in respect of any matter relating to an offence not compoundable under any law. The jurisdiction of the Permanent Lok Adalats is upto Rs. 1 Crore.
The award of the Permanent Lok Adalat is final and binding upon the parties.
Before the dispute is brought before any court, any party to the dispute may make an application to the Permanent Lok Adalat for settlement of the dispute. After an application is made to the Permanent Lok Adalat, no party to that application shall invoke jurisdiction of any court in the same dispute.