Lokayukta Cannot Be A Battlefield For Settling Personal Scores: Karnataka HC

The Karnataka High Court recently dismissed a writ petition filed by a complainant challenging the closure of his complaint by the Lokayukta, emphasizing that public authorities should not be dragged into private family disputes to settle personal scores. A bench of Justice D. K. Singh and Justice T. M. Nadaf heard the challenge against orders that refused to investigate allegations regarding katha alterations while a civil suit was pending.

In its reasoning, the Court observed: "The public authorities cannot be dragged into the battlefield to settle the private and personal scores between the family members. The Courts cannot be made as a battleground for settling the personal scores in respect of private rights between the family members, which amounts to gross abuse of legal process and the same has been considered by the Lokayukta stating that the grievance made are excluded under Section 8(1)(b) to conduct an investigation in the matter."

No Power to Review Own Orders Under Lokayukta Act

The Court noted that the Karnataka Lokayukta Act, 1984 does not enjoin the power of review upon the Lokayukta. Once a complaint has been closed after consideration, a second complaint on the same grievance is barred under Section 8(1)(b) of the Act. The Court clarified that if a party is aggrieved by the Lokayukta's decision, they must approach the appropriate forum rather than filing repeated applications for reconsideration.

Civil Courts Are Proper Forum for Title Disputes

Addressing the core of the dispute the validity of a Will and subsequent katha entry the Court reaffirmed that revenue entries are not documents of title. The Court held that revenue officials and Panchayat Development Officers (PDO) lack the authority to deliberate on property titles. Such rights must be declared by a Civil Court in appropriate proceedings. The Court has the following directions:

"The petition sans merits and is accordingly, dismissed. However, no order as to costs. In view of dismissal of the Writ Petition, pending interlocutory applications, if any, stand disposed of."

Background:

The petitioner, Shreyas P, had applied for a katha change in 2018 at Kannur Grama Panchayat, which was not processed. Through an application under the Right to Information Act in 2023, he discovered that the katha had already been changed 11 months prior in favor of one K.N. Jayasankar, based on a Will dated 2014. The petitioner alleged that Jayasankar, an Ex-Panchayat President, had used his influence to effect a katha based on a fabricated document.

A civil suit (O.S.No.70/2019) regarding the property was already pending. The petitioner filed a complaint with the Karnataka Lokayukta, which was closed on 21.10.2024 under Section 8(1)(b) of the Karnataka Lokayukta Act, 1984. A subsequent complaint based on new documents obtained via RTI was also closed on 19.11.2025.

The petitioner argued before the High Court that his complaint constituted 'allegations' rather than a 'grievance', citing T. N.Raviprakash v. State of Karnataka And Others to claim that the bar under Section 8(1)(b) should not apply. However, the High Court distinguished the cited precedent, noting that the present case clearly involved a private family dispute being pursued through public authorities as an "arm-twisting measure."

Case Details:
Case No.: WRIT PETITION NO. 38917 OF 2025 (GM-KLA)
Case Title: SHREYAS P v. KARNATAKA UPA LOKAYUKTA AND OTHERS
Appearances:
For the Petitioner(s): SMT. USHA PRAKASH, ADVOCATE
For the Respondent(s): SRI. M.N. SUDEV HEGDE, AGA FOR R3

Source: 2026 CaseBase(KAR) 206