In Brief
The Supreme Court held that an Award passed by a Lok Adalat under the Legal Services Authorities Act, 1987 cannot form the basis for redetermination of compensation under Section 28A of the Land Acquisition Act, 1894. The Court clarified that while Section 21 of the 1987 Act deems such Awards to be decrees for enforceability purposes, this legal fiction does not extend to treating them as Awards passed under Part III of the Land Acquisition Act by a Court as defined therein. Since Lok Adalats facilitate compromise and settlement rather than judicial adjudication, their Awards—being products of compromise between parties—cannot serve as foundation for third parties to claim redetermination of compensation. The Court approved the Bombay High Court's narrower interpretation, holding that Section 28A requires adjudication by a Court, not mere compromise.
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