Valid service on advocate in forfeiture proceedings starts limitation when the order is served on counsel.

An advocate engaged in pending proceedings is an authorised agent for service of notices and orders unless the governing statute provides otherwise. Under section 22 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, service of the forfeiture order on the petitioners' advocate was valid because an advocate's authority extends to receiving process relating to the matter. The Tribunal distinguished the authorities relied on by the petitioners and treated the continued authority of the pleader until termination of proceedings as relevant. Limitation for filing the appeal therefore ran from the date of service on the advocate.

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Issues: Whether service of the forfeiture order on the petitioners' advocate was valid service under section 22 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, and whether limitation for filing the appeal started from that service.

Analysis: Section 22 permits service of a notice or order either on the person intended or on his agent. The Tribunal held that an advocate engaged in a case is authorised not only to appear and act for the client, but also to receive notices and orders relating to that matter. The authorities relied on by the petitioners were distinguished on the footing that they did not negate the recognised authority of an advocate in pending proceedings, and the continuation of the pleader's authority until termination of the proceedings was treated as relevant.

Conclusion: Service on the petitioners' advocate was proper service within the meaning of section 22 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, and limitation began to run from that date.

Ratio Decidendi: For purposes of statutory service on a party in pending proceedings, an advocate engaged in the case is an authorised agent competent to receive notices and orders on the client's behalf unless the statute provides otherwise.

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