Limitation applies to compensation restoration proceedings before a statutory authority exercising judicial power and binding adjudication.

A statutory authority exercising judicial power to decide disputes, record evidence, follow civil procedure and issue binding enforceable orders is a court for limitation purposes, not merely a persona designata. On that basis, the Limitation Act, 1963 applied to proceedings before the Commissioner under the Workmen's Compensation Act. An application to restore a compensation claim dismissed for default was treated as an application to set aside dismissal for default and was therefore subject to the specific limitation period, not the residuary article. The restoration request was found to be time-barred, and the order restoring the claim was quashed, with the matter remitted for consideration of the delay question.

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Issues: Whether the Commissioner under the Workmen's Compensation Act is a court for purposes of the Limitation Act and whether an application to restore a compensation claim dismissed for default was barred by limitation.

Analysis: The statutory scheme conferred on the Commissioner adjudicatory powers of a judicial character, including the authority to decide disputed questions between parties, receive evidence, follow procedure akin to the Code of Civil Procedure, and pass binding and enforceable decisions. On the tests drawn from the case law, the Commissioner functioned as a court and not merely as a persona designata. Once so characterised, the Limitation Act, 1963 applied to proceedings before him. The restoration application, being in substance an application to set aside a dismissal for default, attracted the specific limitation period and could not be governed by the residuary article. As the restoration request was presented long after the prescribed period and no explanation covered the delay, the impugned order restoring the claim case could not stand.

Conclusion: The restoration application was barred by limitation, and the order allowing restoration was liable to be set aside in favour of the appellant.

Final Conclusion: The writ rule succeeded, the restoration order was quashed, and the matter was sent back to the Commissioner for consideration of the delay question after giving the workman an opportunity to explain it.

Ratio Decidendi: A statutory authority is a court for limitation purposes when it exercises state-derived judicial power to adjudicate lis between parties by a binding, reasoned, and enforceable decision after following prescribed procedure; once so characterised, the relevant limitation provisions apply to restoration proceedings before it.

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