Limitation and wrong-forum relief were denied where writ proceedings did not justify exclusion of delay in filing appeals.

Under the Prevention of Money Laundering Act, appeals had to be filed within the statutory period, and condonation depended on sufficient cause. The Karnataka HC held that the appellants could not rely on earlier writ proceedings to claim exclusion of time under Section 14 of the Limitation Act because the adjudicating authority's order had not been specifically challenged, the writ petitions proceeded on an incorrect assumption that appeals were already filed, and no bona fide prosecution before the wrong forum was shown. The Court found the delay unexplained and the appellants negligent in pursuing the correct remedy. As a result, the delay was not condoned and Section 14 relief was denied.

---

---

Issues: Whether the appellants were entitled to condonation of the inordinate delay in filing the appeals against the adjudicating authority's order, and whether the delay could be excused on the ground that earlier writ proceedings amounted to prosecution before the wrong forum so as to attract the benefit of limitation principles.

Analysis: The appeals against the adjudicating authority's order were required to be filed within the statutory period prescribed under Section 26(3) of the Prevention of Money Laundering Act, 2002, with condonation possible only on sufficient cause being shown. The Court held that the adjudicating authority's order had not been specifically challenged in the writ petitions, that the writ petitions had proceeded on an incorrect statement that appeals had already been filed, and that there was no credible basis to invoke Section 14 of the Limitation Act, 1963. The Court further held that the appellants had been negligent in not pursuing the correct remedy in time, and that the delay was not explained by bona fide conduct.

Conclusion: The delay was not liable to be condoned, and the appellants were not entitled to the benefit of Section 14 of the Limitation Act, 1963.

---