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Issues: Whether an application under Section 91 of the Punjab Land Revenue Act could be entertained after the prescribed period by applying Section 5 of the Limitation Act, 1963 through Section 29(2) of that Act, and whether the authority lacked power to condone delay merely because the application was made before a revenue authority and not a civil court.
Analysis: The application to set aside the sale was governed by a special law prescribing a limitation period. Section 29(2) of the Limitation Act, 1963 applies where a special or local law prescribes a period different from that in the Schedule, and in such a case the provisions of Sections 4 to 24 apply unless expressly excluded. The absence of an identical entry in the Schedule did not prevent the operation of Section 29(2). Nor was the applicability of the Limitation Act confined to proceedings before civil courts, since the statutory language is wide enough to cover applications before a persona designata or revenue authority. No express exclusion was shown in the Punjab Land Revenue Act. Even apart from this, the authority was bound to consider whether sufficient cause existed and could not refuse jurisdiction on the mistaken premise that it had no power at all to entertain a delayed application.
Conclusion: Section 5 of the Limitation Act, 1963 was applicable, and the revenue authority had power to entertain the delayed application if sufficient cause was shown.
Ratio Decidendi: Where a special or local law prescribes its own limitation period and does not expressly exclude Sections 4 to 24 of the Limitation Act, 1963, the beneficent provisions of the Limitation Act, including condonation of delay, apply even to proceedings before a non-civil authority.