Residuary limitation under Article 137 does not automatically apply to Copyright Board proceedings where civil-court status is limited by statute.

Article 137 of the Limitation Act was considered in relation to an application under Section 50 of the Copyright Act, where no specific limitation period is prescribed. The Gujarat HC noted that the Copyright Board is treated as a civil court only for limited purposes expressly set out in the Copyright Act, and that its civil-court-like powers under Section 74 are confined to those express instances. On that basis, the residuary limitation provision in Article 137 was not applied to the Board in the circumstances considered, and no jurisdictional error was found in entertaining the rectification application.

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Issues: Whether Article 137 of the Limitation Act, 1963 applies to an application under Section 50 of the Copyright Act, 1957 and whether the Copyright Board is a civil court for that purpose.

Analysis: Section 50 of the Copyright Act does not prescribe a specific limitation period. Section 12(7) of the Copyright Act deems the Copyright Board to be a civil court only for the limited purposes stated in the Act, while Section 74 confers specific civil-court-like powers only where expressly provided. The Board's decision to entertain the rectification application involved a discretionary determination on limitation, and no jurisdictional error or legal infirmity was shown. Article 137, being the residuary provision for applications, was not held applicable to proceedings before the Copyright Board in the circumstances of the case.

Conclusion: The challenge to the Board's order failed, and the appeal was dismissed.

Ratio Decidendi: Article 137 of the Limitation Act applies only to applications before a civil court, and where the statute confines civil-court status of a tribunal to specified purposes, that tribunal cannot be treated as a civil court for general application of residuary limitation.

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