The Allahabad High Court has underscored the mandatory nature of the conciliation process under Section 22-C of the Legal Services Authority Act, 1987 before Permanent Lok Adalats proceed to adjudicate disputes. In a significant ruling, the Court set aside an order passed by the Permanent Lok Adalat, Saharanpur, for failing to comply with the statutory conciliation requirements, remitting the matter for fresh consideration.
Background & Facts
The Dispute
The petitioner, Indiafirst Life Insurance Company Limited, challenged an order dated 17.07.2025 passed by the Permanent Lok Adalat, Saharanpur, in P.L.A. Case No. 23/2019. The dispute arose from the Lok Adalat's failure to conduct the mandatory conciliation process under Section 22-C of the Legal Services Authority Act, 1987, before proceeding to adjudicate the matter on merits.
Key Facts
The petitioner was a party to a dispute before the Permanent Lok Adalat, Saharanpur
The Lok Adalat attempted to settle the matter through compromise but failed
The impugned order stated: "All attempts were made by this Permanent Lok Adalat to get the matter settle through compromise, but opposite party Insurance Company refused to co-operate in reconciliation proceedings"
The Lok Adalat proceeded to adjudicate the matter without detailed compliance with Section 22-C
Procedural History
P.L.A. Case No. 23/2019: Dispute filed before Permanent Lok Adalat, Saharanpur
17.07.2025: Impugned order passed by Permanent Lok Adalat, Saharanpur, proceeding to adjudication without proper conciliation
30463 of 2025: Writ Petition filed before the Allahabad High Court challenging the impugned order
Relief Sought
The petitioner sought quashing of the impugned order dated 17.07.2025 and remittal of the matter to the Permanent Lok Adalat for fresh consideration in compliance with Section 22-C of the Legal Services Authority Act, 1987.
The Legal Issue
The central question was whether the Permanent Lok Adalat is legally bound to conduct a detailed conciliation process under Section 22-C of the Legal Services Authority Act, 1987, before proceeding to adjudicate a dispute on merits, and whether a mere general reference to conciliation attempts suffices.
Arguments Presented
For the Petitioner
Relied on the judgment in Manager Life Insurance Corporation of India, Basti vs. Permanent Lok Adalat, Basti and others, 2021:AHC:151400, which held that Section 22-C mandates a thorough conciliation process
Argued that the impugned order failed to demonstrate compliance with the statutory requirements, rendering it legally deficient
Contended that the Lok Adalat's general reference to conciliation attempts was insufficient and did not meet the legal standard
For the Respondent
The Standing Counsel for the State-Respondents did not dispute the legal position regarding the mandatory nature of the conciliation process
Acknowledged that the impugned order lacked detailed compliance with Section 22-C
The Court's Analysis
The Court conducted a detailed examination of Section 22-C of the Legal Services Authority Act, 1987, and the precedent set in Manager Life Insurance Corporation of India, Basti vs. Permanent Lok Adalat, Basti and others. The Court observed:
"The requirement for process of conciliation as provided under Section 22-C of Legal Services Authority Act, 1987, was not carried out by Permanent Lok Adalat in impugned order, except a general reference which is not sufficient."
The Court emphasized that Section 22-C imposes a mandatory duty on the Permanent Lok Adalat to:
Initiate conciliation proceedings between the parties
Facilitate a settlement through detailed efforts
Document the conciliation process thoroughly before proceeding to adjudication
The Court held that a mere general reference to conciliation attempts, as in the impugned order, does not satisfy the statutory requirements. The judgment in Manager Life Insurance Corporation of India, Basti was cited to reinforce that the conciliation process must be exhaustive and well-documented.
The Court further noted that the impugned order contained only a cursory mention of conciliation attempts, stating:
"All attempts were made by this Permanent Lok Adalat to get the matter settle through compromise, but opposite party Insurance Company refused to co-operate in reconciliation proceedings."
This, the Court held, was insufficient to meet the legal standard under Section 22-C.
The Verdict
The Allahabad High Court allowed the writ petition, setting aside the impugned order dated 17.07.2025 passed by the Permanent Lok Adalat, Saharanpur, in P.L.A. Case No. 23/2019. The matter was remitted to the concerned respondent for fresh consideration, with directions to comply with the mandatory conciliation process under Section 22-C of the Legal Services Authority Act, 1987, as interpreted in Manager Life Insurance Corporation of India, Basti vs. Permanent Lok Adalat, Basti and others.
What This Means For Similar Cases
Mandatory Compliance with Conciliation Process
Practitioners must ensure that Permanent Lok Adalats strictly comply with Section 22-C before proceeding to adjudication
A general reference to conciliation attempts is insufficient; the process must be detailed and documented
Failure to comply with the statutory requirements may render the adjudication order legally vulnerable to challenge
Remedies for Non-Compliance
Parties aggrieved by deficient conciliation processes can approach the High Court through writ petitions
The Court may set aside orders passed without proper compliance and remit the matter for fresh consideration
Practitioners should cite Manager Life Insurance Corporation of India, Basti vs. Permanent Lok Adalat, Basti and others to argue for strict adherence to Section 22-C
Implications for Lok Adalats
Permanent Lok Adalats must prioritize conciliation and document their efforts meticulously
Adjudication should be a last resort, only after exhaustive conciliation attempts
The judgment reinforces the procedural safeguards under the Legal Services Authority Act, ensuring fairness and legal compliance
