Time limit for award submission cannot be extended retrospectively where the statute gives no express power to do so.

Where an adjudicator was required to submit an award within the time fixed in the reference order, the State Government had no implied power under the U.P. Industrial Disputes Act, 1947, to enlarge that period after it had expired. Section 14 of the U.P. General Clauses Act, 1904, did not permit alteration of a previously fixed time limit, and section 21 could not retrospectively validate an award made after the authority had become functus officio. An award made beyond the original period was therefore without jurisdiction and void.

---

---

Issues: Whether the State Government had power to extend, after expiry of the original time limit, the period for submission of the award by the adjudicator under the U. P. Industrial Disputes Act, 1947, and whether an award made after the expiry of that period could be validated by a later governmental notification.

Analysis: The power under section 6(1) of the U. P. Industrial Disputes Act, 1947, required the award to be submitted within the time specified in the order of reference. The Act contained no express provision authorising the Government to enlarge that time for the initial award, unlike statutes and rules that expressly confer a power of extension. Section 14 of the U. P. General Clauses Act, 1904, permitted exercise of power from time to time, but did not imply a power to alter an earlier time limit already fixed. Section 21 of that Act also did not assist, because an amendment or modification made after the adjudicator had become functus officio could not operate retrospectively to validate an award already made without jurisdiction.

Conclusion: The State Government had no power to extend the time ex post facto, and the award made after expiry of the original time limit was without jurisdiction and void.

Final Conclusion: The appeal succeeded and the award was set aside as a nullity.

Ratio Decidendi: Where a statute requires an award to be made within a specified time and does not expressly authorise extension, the authority becomes functus officio on expiry of that time, and a later order cannot retrospectively validate an award already made without jurisdiction.

---