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Issues: Whether the Special Court could condone the delay in filing an objection petition under section 4(2) of the Special Courts (Trial of Offences Relating to Transactions in Securities) Act, 1992, and whether section 29(2) of the Limitation Act, 1963 made section 5 of that Act applicable to such proceedings.
Analysis: The period of 30 days prescribed for filing an objection under section 4(2) was held to be mandatory, not merely directory. The language of the provision was unqualified and did not leave room for any inherent power in the Special Court to extend time. The statute itself contained an express power to condone delay only in appeals under section 10(3), and this, together with the overriding clause in section 13, showed that Parliament intended to exclude the application of the Limitation Act to objections under section 4(2). The Court held that section 29(2) of the Limitation Act could not be invoked to import section 5 into the special statute in the face of such express and necessary exclusion.
Conclusion: The Special Court had no power to condone delay under section 4(2), section 29(2) of the Limitation Act, 1963 did not apply, and the belated objection was rightly rejected.
Ratio Decidendi: Where a special statute prescribes a mandatory limitation period and expressly provides condonation only in specified proceedings, the Limitation Act, 1963 is excluded by necessary implication for other proceedings under the same statute.