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Issues: Whether the 14-day period for applying to be substituted as petitioner under Section 110 of the Representation of the People Act, 1951, runs from publication of the withdrawal notice in a newspaper or only from publication in the Official Gazette.
Analysis: Section 110(3)(b) requires the High Court to direct publication of the withdrawal notice in the Official Gazette and in such other manner as it may specify. The publication in another manner is additional to, and not a substitute for, publication in the Official Gazette. Accordingly, where newspaper publication precedes Gazette publication, the limitation period under Section 110(3)(c) ordinarily begins only from the Gazette publication. The High Court had computed limitation from the newspaper publication and not from the Gazette publication.
Conclusion: The substitution applications were within the statutory period and were not barred by limitation.
Final Conclusion: The order dismissing the substitution applications was set aside and the matter was remitted to the High Court to proceed on the basis that the substitution application had been filed in time.
Ratio Decidendi: Where a statute requires publication of a notice in the Official Gazette and also in another specified manner, limitation tied to such publication begins from the Gazette publication unless the statute clearly provides otherwise.