Arbitration challenge limitation starts only on proper delivery of the signed award; the outer delay limit remains absolute.

Delay beyond the additional thirty-day period for filing objections under Section 34 of the Arbitration and Conciliation Act, 1996 cannot be condoned by invoking the Limitation Act, because the statute fixes an outer limit that cannot be enlarged. The article also notes that limitation for challenging an award begins only on proper delivery of a signed copy under Section 31(5); indirect knowledge or defective service does not start time running. On the stated facts, there was no reliable proof of duly served delivery, so the objection period had not commenced and the challenge could not be treated as time-barred.

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Issues: (i) Whether delay beyond the statutory period for filing objections under Section 34 of the Arbitration and Conciliation Act, 1996 could be condoned by resort to the Limitation Act; (ii) Whether the limitation period for filing objections had commenced when the arbitral award was not duly delivered to the officer concerned of the appellant.

Issue (i): Whether delay beyond the statutory period for filing objections under Section 34 of the Arbitration and Conciliation Act, 1996 could be condoned by resort to the Limitation Act.

Analysis: The statutory scheme of Section 34(3) permits filing of objections within three months from delivery of the award, with a further outer period of thirty days, but not thereafter. Section 29(2) of the Limitation Act excludes the application of Section 5 where the special statute expressly bars enlargement of time. The earlier authorities applied to the Arbitration Act, 1940 and to different factual settings, and did not dilute the express limitation built into the 1996 Act.

Conclusion: Delay beyond the additional thirty-day period could not be condoned, and the Court had no power to enlarge time after that outer limit.

Issue (ii): Whether the limitation period for filing objections had commenced when the arbitral award was not duly delivered to the officer concerned of the appellant.

Analysis: Section 31(5) makes delivery of a signed copy of the award to each party a substantive requirement. The Court held that such delivery must be made to the person properly concerned with the dispute or to the corporation in the manner required by law, and that mere indirect knowledge or defective service would not start limitation. On the facts, there was no reliable proof that the award had been duly served on the appellant in the manner contemplated by the statute.

Conclusion: The limitation period had not commenced, so the objections could not be treated as time-barred.

Final Conclusion: The dismissal of the objections and the refusal to condone delay were set aside, and the objections were directed to be heard on merits because the statutory requirement of delivery of the award had not been complied with.

Ratio Decidendi: Under the Arbitration and Conciliation Act, 1996, the outer limit in Section 34(3) is absolute, but limitation begins only upon proper delivery of the signed award under Section 31(5); without such service, the period for challenging the award does not start.

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