Special limitation under SAFEMA excludes Section 5 condonation and bars delay beyond the statutory outer limit.

Section 12(4) of SAFEMA prescribes a self-contained appeal limitation regime: an appeal must be filed within 45 days of service of the order, and may be entertained only up to a maximum of 60 days on sufficient cause shown. Because the special statute fixes this outer limit and gives overriding effect under section 24, the general condonation power in section 5 of the Limitation Act, 1963 is excluded. Delay beyond 60 days therefore cannot be condoned in appeals under SAFEMA.

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Issues: Whether section 5 of the Limitation Act, 1963 applies to an appeal filed under section 12(4) of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976, and whether delay beyond the statutory maximum of 60 days can be condoned.

Analysis: Section 12(4) of SAFEMA prescribes an appeal period of 45 days from service of the order and further permits entertainment of an appeal only up to 60 days if sufficient cause is shown. The proviso thus creates a self-contained limitation scheme with a capped period of condonation. SAFEMA is a special enactment with overriding effect under section 24, and the statutory language was treated as an express bar to the general power of condonation under section 5 of the Limitation Act, 1963. Since the Tribunal is not empowered to extend time beyond the outer limit fixed by the special statute, section 5 cannot be invoked to enlarge the period.

Conclusion: Section 5 of the Limitation Act, 1963 does not apply to appeals under SAFEMA, and delay beyond 60 days cannot be condoned.

Ratio Decidendi: Where a special statute prescribes a complete limitation scheme and fixes an outer limit for condonation, the general power under section 5 of the Limitation Act, 1963 is excluded by necessary implication or express bar.

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