Revisional delay and discretion: unexplained belated petitions may be refused even without an express limitation period.

Where a revisional statute contains no express limitation period, the revisional authority is not compelled to entertain every delayed petition on merits. The Punjab HC held that revisional jurisdiction may be declined where the filing is after unreasonable delay and the petitioner offers no cogent or satisfactory explanation. It approved refusal to entertain a revision filed after about 90 days in the absence of adequate cause, treating this as a proper exercise of discretion rather than a denial of the statutory remedy.

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Issues: Whether the Financial Commissioner was bound to consider a revision petition on merits despite delay in filing it.

Analysis: Section 21 of the Punjab General Sales Tax Act, 1948 vested revisional power in the Financial Commissioner but prescribed no express period of limitation. The Court held that the absence of a statutory limitation period did not compel the Financial Commissioner to entertain every delayed revision. Revisional jurisdiction could be declined where the petition was filed after unreasonable delay and no cogent explanation was offered. The Court approved the view that entertaining revision petitions filed after about 90 days, in the absence of a satisfactory explanation for delay, was a proper exercise of discretion and did not render the revisional remedy illusory.

Conclusion: The Financial Commissioner was not bound to decide the delayed revision petition on merits, and refusal to entertain it was valid.

Ratio Decidendi: In the absence of an express statutory limitation, a revisional authority may, in the exercise of judicial discretion, refuse to entertain a belated revision petition where the delay is unexplained or not satisfactorily accounted for.

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