Limitation applies to statutory review proceedings where no special period is prescribed, and mistaken belief does not excuse delay.

A review remedy under section 15(6) of the Rajasthan Sales Tax Act was treated as a judicial proceeding governed by the High Court procedure, and the Limitation Act applied through section 29(2) because the special Act did not prescribe a different limitation period. The applicable review period was 30 days, so the review filed after 81 days was time-barred. A plea of bona fide belief that no limitation existed was held insufficient to establish sufficient cause for condonation of delay.

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Issues: Whether the review application under section 15(6) of the Rajasthan Sales Tax Act, 1954 was governed by the limitation period under the Limitation Act, and whether the delay of 81 days could be excused on the basis of bona fide belief and absence of an express limitation in the special Act.

Analysis: The remedy of review under section 15(6) was treated as a judicial proceeding for which the procedure of the High Court applied. The expression used in the special provision was held to fall within the broader judicial meaning of an order or judgment. The absence of an express period in the Rajasthan Sales Tax Act did not exclude the operation of the Limitation Act, because section 29(2) attracted the general law where the special law did not prescribe a different limitation. The Court held that the applicable period for review was 30 days, and that the review filed beyond that period was time-barred. The plea that the petitioner honestly believed that no limitation applied was held insufficient to constitute sufficient cause.

Conclusion: The review application was barred by limitation and the explanation for delay was rejected; the outcome was against the petitioner and in favour of the assessee.

Ratio Decidendi: Where a special statute creates a review remedy but does not prescribe a limitation period, the Limitation Act applies by virtue of section 29(2), and delay cannot be ignored merely because the applicant assumed that no time limit existed.

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