Court-restraint period may be excluded from registration time limits, but late presentation beyond the statutory period remains invalid.

Where a competent court's interim order prevents presentation of a document for registration, the blocked period may be excluded on the principles that no one can be compelled to do the impossible and that an act of court should prejudice none. The Registration Act's time limits for presentation, however, remain mandatory: if the document is still presented beyond the permissible period even after excluding the restrained interval, the registering officer has no authority to admit it and the registration is invalid and ineffective.

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Issues: (i) Whether the period during which registration was restrained by a court order could be excluded while computing the time limit under the Registration Act. (ii) Whether presentation and registration of the award after the statutory period was valid.

Issue (i): Whether the period during which registration was restrained by a court order could be excluded while computing the time limit under the Registration Act.

Analysis: The statutory scheme under Sections 23 and 25 of the Registration Act fixes the time for presentation of a document for registration, but the Court held that where a competent court has by interim order prevented the parties from proceeding with registration, the general principles that a person cannot be compelled to do the impossible and that an act of the court should prejudice none apply. The Court also relied on the principle that time during which proceedings are stayed by court order should be excluded in computing limitation, and treated the restraint order as a ground for exclusion of the relevant period.

Conclusion: The restrained period was liable to be excluded in computing the time for presentation for registration.

Issue (ii): Whether presentation and registration of the award after the statutory period was valid.

Analysis: Even after excluding the period covered by the restraint order, the award was still presented many years after its execution and far beyond the outer limit contemplated by Sections 23 and 25 of the Registration Act. On that footing, the Registration Officer had no authority to admit the award to registration and the registration could not be sustained as valid or effective.

Conclusion: The registration was invalid and ineffective.

Final Conclusion: The petition succeeded, the impugned registration was quashed, and the award was held incapable of being registered on the facts before the Court.

Ratio Decidendi: Where a party is prevented from presenting a document for registration by a subsisting court order, the blocked period may be excluded on general principles, but if the document remains out of time even after such exclusion, registration contrary to the mandatory time limit is invalid.

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