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As of 9 November 2026, which of the following is not a dispute resolution mechanism under section 89 of…

Section 89(1) lists arbitration, conciliation, judicial settlement including settlement through Lok Adalat, and mediation. The Supreme Court in Afcons Infrastructure Ltd. v.…

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As of 9 November 2026, which of the following is not a dispute resolution mechanism under section 89 of the Code of Civil Procedure, 1908?

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Answer and explanation

Correct answer D

Section 89(1) lists arbitration, conciliation, judicial settlement including settlement through Lok Adalat, and mediation. The Supreme Court in Afcons Infrastructure Ltd. v. Cherian Varkey Construction Co. read section 89 with Order X, rule 1A and treated Lok Adalat and judicial settlement as separate routes. Collective bargaining concerns negotiation between employers and workers' representatives and does not appear among the section 89 routes.

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Option A

Judicial settlement is listed in section 89(1)(c). Afcons treats it separately from a reference to Lok Adalat.

Option B

Incorrect because conciliation is expressly enumerated as an ADR mechanism in Section 89(1)(b) of the Code of Civil Procedure, 1908.

Option C

Incorrect because mediation is expressly enumerated as an ADR mechanism in Section 89(1)(d) of the Code of Civil Procedure, 1908.

Option D

Collective bargaining is a labour-relations process. It is not a route listed under section 89.

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