Alternative Disputes Resolution: An overview of Non Adjudicatory Methods

The Author is Pooja Bali currently serving as Assistant Professor of Law at Himcapes School of Law.

ADR is different that from judicial process. Under ADR disputes are settled with the assistance of a neutral third person generally of parties’ own choice; that person is generally familiar with the nature of the dispute. Here the proceedings are informal without any procedural technicalities. It is expeditious, inexpensive and confidential. Thus the decision making process aims at substantial justice. The goal is to provide more effective dispute resolution. Availability of ADR creates more choices within the justice system. The alternative movement is not just a response to judicial administrative shortcomings; it is also a demand for higher standards of justice. The movement and concern for alternatives, including alternatives to the courts as well as alternatives in the courts also represent a desire to move the justice system closer to the people and their problems, needs, perceptions and understandings.
Alternative Dispute Resolution (ADR, sometimes also called ‘Appropriate Dispute Resolution’) is a general term, used to define a set of approaches and techniques aimed at resolving disputes in a non-confrontational way. It covers a broad spectrum of approaches, from party-to-party engagement in negotiations as the most direct way to reach a mutually accepted resolution, to arbitration and adjudication at the other end, where an external party imposes a solution. Somewhere along the axis of ADR approaches between these two extremes lies “mediation,” a process by which a third party aids the disputants to reach a mutually agreed solution.[1] The technique of ADR is an effort to design a workable and fair alternative to one traditional judicial system. It is a fast track system of dispensing justice. These measures are being taken throughout the world for resolving pending disputes as well as at pre- litigation stage. The law commission noted that in all developed systems normally not more than 15% of the cases go for final adjudication. The rest of the cases are resolved by alternative dispute resolution mechanisms like conciliation, mediation and arbitration. Pre-trial conciliation accounts for the disposal of a large number of cases. ADR has emerged as a significant movement in these countries and has not only helped reduce cost and time taken for resolution of disputes but also in providing a congenial atmosphere.
Non- adjudicatory methods of conflict resolution are also available and must be used. These include negotiation, conciliation and mediation. In general, these are less formal, encourage disputants to communicate and participate in the search for solutions, focus better on the root issues of the conflict, save relationships and have considerable savings in time and cost. Mediation, Conciliation and Arbitration are historically more ancient than Anglo-Saxon adversarial system of law. Mediation was very popular amongst businessmen during pre-British rule in India. Businessmen used to resolve disputes between members of the business associations. All these non adjudicatory techniques are employed in the new concept of Lok Adalats.
Conflicts have existed in all cultures, religions and societies since time immemorial. There is a common belief in all cultures that it is best to resolve disputes and to reach an agreed end to them, because conflict is a destructive force. There are fears that the system is collapsing. Many suffer injustice because they are frightened of approaching the legal system. The resolution  offered by the courts does not deal with the substantive issue in dispute or give the parties an effective solution and end to their conflict. Effective reform lies in measures which promote both efficiency and ethics. The adversarial system is the appropriate method in a number of situations especially those needing authoritative interpretation or establishment of rights or which manifest severe negotiating imbalance. It is also required as a last resort of resolution.
Court annexed mediation is comparatively a new phenomenon. This concept owes much of its origin from the notion of ‘multi door courthouse’ propounded by Frank E.A. Sander – an American Professor. In 1976, Professor E.A. Sander had proposed the idea of a multi door courthouse where individual disputes would be matched 167 to appropriate processes such as mediation, arbitration or fact finding. According to him, court room should be a comprehensive justice centre where disputes would be analyzed according to various criteria to determine what mechanism would be best suited for the resolution of the problem.[2]His idea was adapted in the American Civil Justice System and court annexed mediation system is a huge success story in the U.S.A.[3]
In comparison to the adjudication (judicial or arbitral), negotiation, mediation and conciliation are private, informal, more mutual, facilitative, future-looking, interest-based processes that bring parties to an adjusted, multi-dimensional, win-win remedy that is more durable because of the parties’ consent in the outcome. The application of mediation and conciliation to the legal dispute resolution process is not intended to replace or supplant the need for public adjudication and pronouncements on the critical issues, but to complement and preserve the judicial system. These alternatives may provide to mitigate some of the pressures currently impeding the performance of current court systems.
Mahatma Gandhi, the father of nation, has also said, “I had learnt the true practice of law. I had learnt to find out the better side of human nature, and to enter men's hearts. I realized that the true function of a lawyer was to unite parties riven as under. The lesson was so indelibly burnt unto me that the large part of my time, during the twenty years of my practice as a lawyer, was occupied in bringing about private compromises of hundreds of cases. I lost nothing, thereby not even money, certainly not my soul.”[4]
One must learn to negotiate in a manner that is less competitive and adversarial, thereby invoking the potential for cooperation. By working together as “joint problem solvers” seeking joint solutions and not working against one another, the participants can “enlarge the pie” that is to be divided. This can be done either by negotiation, or with the help of an impartial third party who will act as mediator. If anyone has a problem with a person or organisation one deals with regularly for example a neighbor, ADR can mean a better, longer-lasting solution to one’s problem. It may also result in better communication with them in the future. The non adjudicatory dispute resolution methods are useful not only for small claims like motor accidents, family disputes and petty crimes but also as an alternative dispute resolution mechanism for the most complex matters, including those involving environmental disputes and intellectual property law disputes which were previously considered to be irreconcilable. In the emerging global markets there is need to resolve disputes quickly and inexpensively as well as amicably, suitably and productively, in order to maximize long-term interests and to maintain continuing commercial relationships. One can also use some ADR schemes as well as going to court or a tribunal. For example, mediation can help everyone focus on the issues that are causing the problem, making it easier for one to reach an agreement or for a judge to make a decision.

Lok Adalats
India has had a long history of resolving disputes through the mediation of village elders. The system of Lok Adalats is an improvement on that and is based on Gandhian principles. The ancient concept of settlement of dispute through mediation, negotiation or through arbitral process known as “Peoples’ Court verdict” or decision of “Nyaya-Panch” is conceptualized and institutionalized in the philosophy of Lok Adalat. Sometimes Lok Adalat seems to be similar to conciliation or mediation or negotiation. It involves people who are directly or indirectly affected by dispute resolution. Participation, adjustment, fairness, expectation, voluntariness, transparency, efficiency and lack of animosity are certainly, all important characteristics of this distinct Indian institution rooted in India’s history, culture and environment[5]

Meaning of Lok Adalat
The expression Lok Adalat comprises two words, namely, ‘lok’ and ‘adalat’ the former expressing the concept of public opinion while the latter denoting the accurate and through deliberation aspect of decision making. In simple terms, this refers to a forum for settlement of disputes, employing ADR techniques, such as Negotiation, Conciliation, and Mediation etc. It is a forum which ensures easier access to justice for the poor. It enables speedy disposal of cases through settlement between parties, supervised by a body of legally competent personalities. The term ‘Lok Adalat’ literally means peoples’ court, but it is not a court in real sense. It is basically a statutory forum for conciliatory settlement of legal disputes.
The concept of Lok Adalat8 is a concept of compromise. At this point lies the importance of this mechanism. The Lok Adalat is an old form of adjudicating system prevalent in ancient India. The concept of Lok Adalats was pressed back into unconsciousness in last few centuries before independence and particularly during the British regime.9 Now, this concept has, once again, been revived. It has become very popular and familiar amongst litigants. This is the system which has deep roots in Indian legal history and its close loyalty to the culture and perception of justice in Indian philosophy. Experience has shown that it is one of the very efficient and important ADRs and most appropriate to the Indian environment, culture and community welfare.

Emergence of Lok Adalat
The concept of Lok Adalats was pushed back into oblivion in last few centuries before independence and particularly during the British regime. Now, this concept has, once again, been rejuvenated. It has, once again, become very popular and familiar amongst litigants. This is the system which has deep roots in Indian legal history and its close allegiance to the culture and perception of justice in Indian ethos. Experience has shown that it is one of the very efficient and important ADRs and most suited to the Indian environment, culture and societal interests. Camps of Lok Adalats were started initially in Gujarat in March 1982 and now it has been extended throughout the Country.
The evolution of this movement was a part of the strategy to relieve heavy burden on the Courts with pending cases and to give relief to the litigants who were in a queue to get justice. The first Lok Adalat was held on March 14, 1982, at Junagarh in Gujarat the land of Mahatma Gandhi. Maharashtra commenced the Lok Nyayalaya in 1984. Lok Adalats have been very successful in settlement of motor accident claim cases, matrimonial/family disputes, labour disputes, disputes  relating to public services such as telephone, electricity, bank recovery cases and so on.
Some statistics may give us a feeling of tremendous satisfaction and encouragement.Upto the middle of last year (2004), more than 200,000 Lok Adalats  have been held and there in more than 16 million cases have been settled, half of which were motor accident claim cases. More than one billion US dollars were distributed by way of compensation to those who had suffered accidents. 6.7 million persons have benefited through legal aid and advice.
Legal Machinery of the Lok Adalats under the Legal Services Authorities Act 1987:
The Indian Legislature made evolution by enacting the Legal Services Authorities Act, 1987. By the enactment of the Legal Services Authorities Act, 1987, which came into force from November 9, 1995, the institution of Lok Adalats received statutory status. The Legal Services Authorities Act, 1987 has been enacted by the Parliament to give effect to the constitutional mandate under Article 39-A for providing access to justice to all by providing suitable legal aid.
 National Legal Services Authority and Other Authorities:
The Legal Services Authorities Act, 1987, displaced the ‘CILAS’ and introduced a hierarchy of judicial and administrative agencies. The Legal Services Authorities Act began to be enforced eight years later, under the directions of the Supreme Court. It led to the constitution of the National Legal Services Authority (NALSA) at the Centre with the Chief Justice of India as its patron in chief and a State Legal Services Authority in the States to give effect to its directions. District Legal Services Authority is constituted in every District to implement Legal Aid Programmes and Schemes in the District. The Central Authority (NALSA) has been vested with several duties to perform. Among others the Central Authority has the duty
 (1) to encourage the settlement of disputes by way of negotiations, arbitration and conciliation. (2) To lay down policies and principles for making legal services available in the conduct of any case before the court, any authority or tribunal.
 (3) To frame most effective and economical schemes for the purpose.
 Ever since the day when the activities of the erstwhile Committee for Implementation of Legal Aid (CILAS) were taken over by National Legal Services Authority (NALSA) in December 1995, NALSA has been endeavoring to implement the objectives of Legal Services Authorities Act, 1987. In addition to the court based legal aid to the categories of persons eligible for free legal services under Section 12 of the Act, NALSA has paid incremental attention to conduct Lok Adalats all over the country as a part of its drive for ADR and also the preventive and strategic legal aid through legal awareness camps. A large number of national and regional level conferences, conventions, workshops and training courses are also being conducted by NALSA throughout the country. Following schemes and measures have been envisaged and implemented by the Central Authority .
(a) Establishing Permanent and Continuous Lok Adalats in all the Districts in the country for disposal of pending matters as well as disputes at pre-litigative stage;
 (b) Establishing separate Permanent & Continuous Lok Adalats for Govt. Departments, Statutory Authorities and Public Sector Undertakings for disposal of pending cases as well as disputes at pre-litigative stage;
(c) Accreditation of NGOs for Legal Literacy and Legal Awareness campaign;
(d) Appointment of “Legal Aid Counsel” in all the Courts of Magistrates in the country;
 (e) Disposal of cases through Lok Adalats on old pattern;
(f) Publicity to Legal Aid Schemes and programmes to make people aware about legal aid facilities;
(g) Emphasis on competent and quality legal services to the aided persons;
(h) Legal aid facilities in jails;
 (i) Setting up of Counseling and Conciliation Centers in all the Districts in the country;
 (j) Sensitization of Judicial Officers in regard to Legal Services Schemes and programmes.
Permanent and Continuous Lok Adalats are being established in all the Districts in the country. Permanent and Continuous Lok Adalats are primarily aimed at settling disputes at pre-litigative stage and more contentious pending matters in District courts in which the parties can be motivated only by repeated sittings to arrive at settlement. NALSA has been providing funds to State Legal Services Authorities for the implementation of the Legal Aid Schemes and Programmes. Separate Permanent and Continuous Lok Adalats in Govt. Departments are aimed at amicably settling pending cases as well as the matters at pre-litigative stage between Govt. Departments and general public so that the inflow of litigation to regular Courts is reduced. In many Govt. bodies these Lok Adalats have become functional. In Delhi Permanent Lok Adalats have been established in Delhi Vidyut Board, Delhi Development Authority, Municipal Corporation of Delhi, MTNL and General Insurance Corporation. It is one of the functions of the State Legal Services Authorities to provide preventive and strategic legal aid. The preventive aspect contemplated is to adopt suitable strategies dissuading the people from getting into unnecessary disputes and 177 wasting their time, energy and money in unnecessary litigation. By doing so, peace is brought back in the society and the resources, both economic and manpower, can be channelized for useful, constructive and nation building process. Strategic Legal Aid also encompasses Alternative Dispute Resolution mechanisms. The ADR mechanisms of Lok Adalat or Mediation and Conciliation are all strategies to be implemented as a part of Legal Aid and Legal Services. The Ultimate objective is to prevent the dispute maturing into expensive, bitter, acrimonious and adversarial litigation. Yet another strategic intervention by legal aid and legal services is by way of creating legal awareness and thereby reducing the chances of coming into conflict with law
Organization of Lok Adalat
The State Authority and District Authority, Supreme Court Legal Services Committee, High Court Legal Services Committee and Taluk Legal Services Committee (mentioned in Section 19 of the Act) can organize Lok Adalats at such intervals and Permanent Lok Adalats as may be deemed fit.
Every Lok Adalat so organized shall consist of:
a.    Serving or retired judicial officers,
b.    Other persons, as may be specified.
The experience and qualification of “other persons” in a Lok Adalat conducted by Supreme Court Legal Services Committee shall be prescribed by the Central Government in consultation with the Chief Justice of India. At present, Rule 13 of the National Legal Services Authorities Rules, 1995 prescribes such experience and qualifications as:
A.   A member of the legal profession; or
B.   A person of repute who is especially interested in the implementation of the Legal Services Schemes and Programmes; or
C.   An eminent social worker who is engaged in the upliftment of weaker sections of people, including Scheduled Castes, Scheduled Tribes, women, children, rural and urban labour.
The experience and qualification of “other persons” mentioned in clause (b) shall be prescribed by the State Government in consultation with the Chief Justice of High Court.
Jurisdiction of Lok Adalat
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-
        i.            Any cases pending before; or
      ii.            Any matter which is falling the jurisdiction of, and is not brought before,
Any court for which the Lok Adalat is organized:
Provided that the Lok Adalat shall have no jurisdiction in respect of any case or matter to an offence not compoundable under any law.
Lok Adalat an Integral Part of Constitution
The concept of Lok Adalat is an integral part of the Indian Constitutional Scheme mentioned in Preamble, Part III and Part IV of the Constitution. Because the Constitution mandates not only to impart justice in its legal sense, but also social, economic, and political sense. Equal justice and free legal aid is a directive principle of state policy imbibed in Article 39A which is particularly concerned with the need of qualitative and effective justice delivery mechanism. The institution of Lok Adalat has been developed in the process of implementation of commitments of the Constitution in order to mitigate not only the problem of justice delays resulting from adjudication of even ordinary disputes by the normal courts procedure but also to dispense less expensive justice quickly with the conciliatory efforts. So, Lok Adalat is a way to achieve the constitution goals enshrined in different provisions.[6]
Lok Adalat Brings Unity in Society
The concept of Lok Adalat is a concept of compromise. Here lies the importance of this mechanism. A society exists because of the give and take relations that binds its members. Social interaction implies accommodation and compromise when it is normal. Minus the spirit of accommodation, interaction perverts into dispute and confrontation. Dispute invites litigation which does not ensure speedy justice.66 In India, where the entire dilatory procedure of litigation exists, the Lok Adalat system can give relief to the disputant. The purpose behind the Lok Adalat is to invoke the consciousness of the community to maintain local unity and to secure equitable and substantial justice. The amicable settlements by the Lok Adalats are not necessarily according to the legal principles. They have their eyes always on social goals like ending feuds rather pending disputes, restoring peace in the family, community and the locality and ultimately providing for destitute law or no law, and also inculcating a nature of amicable settlement of disputes among the people.
Lok Adalats involve the people in its proceeding which infuse the spirit of unity, amity and peace among the litigants. Apart from being a method of mobilizing and involving the people in the judicial process at the grass-root level, the Lok Adalat has social advantage of seeing the parties returning happily to their respective homes relieved from bickering and enmity lingering on up to generations.[7] Because if the disputes are resolved through Lok Adalats, parties may be saved from protracted litigation, anxiety, botheration and bitterness, the large amount of expenses or court fees and other expenses which they are likely to incur in future litigation by way of further appeal, etc. The Lok Adalats have a direct impact on the people’s mind disclosing that the common man yearning for justice leaves the place of Lok Adalat with happiness and satisfaction. In Lok Adalat, there is neither victor, nor a vanquished, but there is victory for both because of concert and conciliation resulting in peace, that a case ends in the Lok Adalat the enemy disappears. By the settling of dispute the old friends and family members re-appear. Therefore, the Lok Adalat does not only provide the happiness to the disputants by resolution of their dispute but also bring unity, peace and order in the society.
 Lok Adalat based on Democratic Principles
The Legal Services Authorities Act fulfills the two objectives namely, granting legal aid services and organizing Lok Adalats for providing justice to the people at their doorsteps. But the legal aid services are provided only to the eligible persons as per the provision76 of the Act. However, in the case of Lok Adalat, the criteria for eligibility for legal aid are not applicable for the very good reason that it should be available in all cases to all persons irrespective of income of the parties, its object being speedier justice at less expense to all parties to the litigation, actual and potential.77 It means that Lok Adalat can take cognizance of matters involving not only those persons who are entitled to avail free legal services but of all other persons also, be they women, men or children and even institutions. In this sense, it provides equal opportunity to all irrespective of caste, religion, sex, race and wealth to present the dispute before Lok Adalat for settlement.
 The Lok Adalats function purely on democratic principles. There is no pressure upon parties to settle the disputes through Lok Adalats. The Lok Adalat is an institution of Indian justice delivery system in which the cases are referred by consent of disputants or by one of the parties or by court suo motu or by the concerned authority or committee.78 Before such reference, a reasonable opportunity of being heard is provided to the parties except where there is a consensus between the parties.
Role of Lawyers in Lok Adalat
It is, generally, said that the lawyers frequently request for adjournments on the flimsiest of grounds which obviously delay in the process of dispensation of justice. Therefore, in the Lok Adalat system, it is not compulsory for lawyers to be appeared on behalf of their parties. The parties are free to settle the matter on the basis of mutual consent. But lawyers are also not prohibited to appear before a Lok Adalat. Lawyers have been showing a commendable sense of participative co-operation in the endeavours aimed at holding successful sittings of Lok Adalat.[8] When a case is referred from a court to Lok Adalat for settlement, the lawyers of the concerned parties are under legal as well as moral obligation to participate in the Lok Adalat proceedings. The appearance of lawyers before Lok Adalat is expected by the society to demonstrate enough commitment to offer their expertise for the achievement and advancement of the noble mission of Lok Adalat. Lawyers are helpful in drafting out the terms of the compromise or settlement, a better marshalling and appreciation of the facts which sometimes may be complex and persuading the parties for settlement of the dispute. Therefore, the role of lawyers in the Lok Adalat is simply of advisory nature and helps their clients to arrive at a compromise through their sweet and sincere efforts.
 Lok Adalat as a Court
Lok Adalat means people’s court but, in its accepted connotation, it is not a court. It is a alternative dispute resolution forum where voluntary efforts intended to bring about settlement of disputes between the parties are made through conciliatory and persuasive efforts. However, the Lok Adalat has got the status of a Civil Court in respect of the matters such as summoning of witnesses, examination of witnesses, discovery of documents, reception of evidences on affidavits, and requisitioning of public record or documents. All proceedings before a Lok Adalat for the determination of the dispute are deemed to be judicial proceedings. The award of Lok Adalat is deemed to be a decree of Civil Court and final and binding on all the parties to the dispute. No appeal can be made to any Court against such award of Lok Adalat.
So far as the implementation aspect of the decision of Lok Adalat is concerned, the moral sanctity, popularity and approval enjoyed by the Lok Adalat have helped it in getting its decision executed and implemented by the disputants. The Lok Adalat does not believe in the coercive method, but relies solely on its moral and social force to have its decisions carried out.  Therefore, most of the disputant voluntarily takes upon themselves the responsibility to fulfil the obligations imposed upon them by the Lok Adalat either because of public pressure upon them or because of the self-realisation of any mistake or offence committed by them and the necessity of rectifying that mistake by fulfilling the obligation imposed by the Lok Adalat in that respect. In present days the Lok Adalat system is governed by Legal Services Authorities Act. As per that Act, the award of Lok Adalat is treated as a decree of civil court from which the case is referred to Lok Adalat for settlement, so, such award can be executed by such court in accordance with the provision of CPC.
 Lok Adalat Strengthen Human Relations
Lok Adalat system is not visualized as a supplant to court system but supplementary machinery to get resolved pending cases in the courts of law. Resolution of cases through Lok Adalat is a composite endeavour.105 The true basis of settlement of dispute by the Lok Adalat is the principle of mutual consent and voluntary acceptance of the solution with the help of conciliator. The basic purpose of Lok Adalat is not merely to give justice based on evidence, law, and legal know-how but the approach is to the very human problem itself. The concept of Lok Adalat revolves around the principle of creating awareness amongst the poor, innocent, illiterate and ignorant people to the effect that their welfare and interest really lies in arriving at immediate and peaceful settlement of their dispute. It is to make them conscious of the fact that the only suitable remedy with them is in getting rid of their case by a single decision through, compromise. It will save not only their hard-earned money, time, but multiplicity of litigation, by being involved in appeal, review, revision, remand, etc., the never ending chain. It is the basic philosophy of the Lok Adalat to see that the tension, enmity, disquietude of the party are shunned away by resolution of their case. Lok Adalat is to generate an environment of friendship by making the people to understand that their relief lies not in enmity by winning the case but by resolution in mutual friendship and brotherhood. It will create an atmosphere of goodwill amongst the parties, which in ultimate analysis will bring peace in the society at large.
Lok Adalat is humanitarian aspect and the basic purpose of the Lok Adalat is not to impose the justice but handling over justice with mutual and free consent of the parties. The people are awakened to their own rights and duties vis-a-vis the rights and duties of others. There is a rational thinking on the part of both the parties to a dispute, without going towards adversary system of proving or disproving guilt. It is seen that both the parties accept a solution as agreed to by them or suggested by the members of Lok Adalat. In this solution, actually none of the disputants is held totally guilty or totally innocent and the dispute or conflict is resolved through conciliation on the give and take’ basis. The Lok Adalats act as a middle agency in finding out a solution which is beneficial and agreeable to both the parties. The procedure and results are really determined in a significant manner by the attitude of the disputants.109 By adopting this attitude, the Lok Adalats strengthen the human relations in society. Thus, the significant objective of Lok Adalat is to settle the disputes by discussions, counseling, negotiations, conciliation and by adopting persuasive commonsense and humane approach to the problems of the disputants. On the basis of features of the Lok Adalat, it is revealed that the main focus of Lok Adalat through its dedicated conciliators is to settle the dispute by adopting the persuasive and conciliatory rules. It does not use the coercive methods for bringing the graceful settlement between the disputants. The award of Lok Adalat is based on the compromise of the parties with their free and mutual consent. The Lok Adalat system does not only fulfil the aspiration of the weaker section of the society but also implement the Indian cultural values and constitutional mandates. It is an unique forum which strengthens the human relations and values and helps to establish the peace, order and unity in the society

[1] Yona Shamir, Alternative Dispute Resolution Approaches and their Application,, site visited on 28.2.2020
[2] Frank E.A. Sander, “Dispute Resolution Within and Outside Courts-An Overview of the US Experience” in P.C.Rao and William Sheffield (eds), Alternative Dispute Resolution: What it is and How it Works, Universal Law Publishing Co., New Delhi, (1997), pp. 123-136.
[3] Dana H. Freyer, “The American Experience in the Field of ADR”, in P.C.Rao and William Sheffield (eds), Alternative Dispute Resolution: What it is and How it Works, Universal Law Publishing Co., New Delhi, (1997), pp. 108-122.
[4] Mahatma Gandhi, The Story of My Experiments with Truth, Part 2, Chapter XIV,
[5] Justice Jitendra N. Bhatt, A round table Justice through Lok-Adalat (Peoples' Court) - A vibrant - ADR - in India, (2002) 1 SCC (Jour) 11
[6] See Constitution of India, Preamble, Arts. 14, 21, 38, 39A and 40.
[7] R.K. Mahajan; “Practical Evaluation of Himachal Pradesh Experiment,” AIR 1988 Jour 136.
[8] D.K. Sharma, “Lawyers and Lok Adalat,” AIR 2004 Jour 251.