Mandatory statutory time limits under a fiscal scheme must be strictly enforced; late payment cannot secure the certificate.

The Kar Vivad Samadhan Scheme, 1998 was treated as a special fiscal scheme requiring strict compliance with the thirty-day payment period in section 90(2). The use of "shall" was read as mandatory, so courts could not relax the statutory deadline or direct issue of a certificate where payment was made late. The authority was therefore correct in declining the benefit after delayed payment, and equitable or mandamus-based relief contrary to the Scheme was unavailable. The article also notes that refusal of special leave in other matters does not amount to affirmation of those decisions, and it preferred the strict-compliance line of authority.

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Issues: Whether the time-limit under section 90(2) of the Kar Vivad Samadhan Scheme, 1998 for payment of the determined amount within thirty days is mandatory and incapable of relaxation, so as to entitle the declarant to the certificate notwithstanding payment made six days late.

Analysis: The Scheme was treated as a special statutory scheme requiring strict adherence to its express time stipulations. The Court relied on the principle that the word "shall" in section 90(2) is mandatory and that judicial relaxation of the prescribed period would amount to rewriting the Scheme. It also held that rejection of special leave against other decisions does not amount to affirmation of those views, and preferred the strict-compliance line of authority, including the Supreme Court's ruling in Hemalatha Gargya. On that basis, the designated authority had acted in accordance with the statutory mandate in declining to issue the certificate after delayed payment.

Conclusion: The delay could not be condoned, the certificate under section 90(2) could not be directed to be issued, and the challenge failed.

Final Conclusion: The statutory time-limit under the Scheme was held to be compulsory, leaving no scope for equitable relaxation or issuance of mandamus contrary to the Scheme, and the writ petition was rejected.

Ratio Decidendi: Where a special fiscal scheme prescribes a fixed time for payment and uses mandatory language, courts must enforce strict compliance and cannot extend the time or direct issuance of benefits contrary to the statute.

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