Section 89 of the Code of Civil Procedure, 1908 represents a legislative effort to institutionalize alternative dispute resolution (ADR) within the Indian civil justice system as a response to mounting judicial pendency. Conceived as an enabling provision, Section 89 empowers courts to refer disputes to ADR mechanisms where elements of settlement appear to exist. However, its practical application has generated significant constitutional and procedural concerns, particularly regarding the erosion of judicial discretion, voluntariness of participation, and party autonomy. This paper critically examines the transformation of Section 89 from a discretionary judicial tool into a quasi-mandatory procedural step in trial court practice. Through doctrinal analysis and judicial interpretation, especially the jurisprudence developed in Salem Advocate Bar Association and Afcons Infrastructure Ltd, the study explores how mechanical and unreasoned referrals to ADR risk converting facilitation into indirect compulsion. The paper further analyses the constitutional implications of such practices under Articles 14 and 21 of the Constitution of India, highlighting concerns of arbitrariness, denial of access to justice, and dilution of procedural fairness. It argues that while ADR serves an important complementary role, its legitimacy depends upon preserving informed consent, suitability assessment, and reasoned judicial application. The paper concludes by advocating a model of structured judicial discretion that reconciles efficiency with constitutional discipline, ensuring that ADR remains a genuine alternative to adjudication rather than an imposed procedural diversion.