Limitation Act applies to special tribunal revisions where no express exclusion exists; earlier contrary view needs larger Bench review.

The Supreme Court considered whether Section 5 of the Limitation Act could be applied to condone delay in a revision under the Madhya Pradesh Madhyastham Adhikaran Adhiniyam, 1983. It reasoned that the Tribunal under the special Act had the trappings of a court and decided disputes in judicial proceedings, so Section 29(2) of the Limitation Act attracted Sections 4 to 24, including Section 5, unless expressly excluded by the special statute. Distinguishing cases involving special limitation schemes, the Court observed that the earlier Division Bench view appeared incorrect and directed placement of the matter before the Chief Justice of India for constitution of a larger Bench.

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Issues: Whether the High Court could condone delay in a revision under Section 19 of the Madhya Pradesh Madhyastham Adhikaran Adhiniyam, 1983 by applying Section 5 of the Limitation Act, 1963, and whether the earlier view that such condonation was impermissible required reconsideration by a larger Bench.

Analysis: The Tribunal under the special Act was held to be a court for the purpose of the Limitation Act, having the trappings of a court and deciding disputes in judicial proceedings. On that reasoning, Section 29(2) of the Limitation Act, 1963 was treated as attracting Sections 4 to 24, including Section 5, unless expressly excluded by the special law. The judgment distinguished authorities where special statutes contained their own restrictive limitation schemes and observed that the earlier Division Bench view appeared not to be correctly decided in the light of the governing principles.

Conclusion: The earlier decision was prima facie found to be erroneous, and the matter was directed to be placed before the Chief Justice of India for constitution of an appropriate larger Bench.

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