Arbitral award challenge limitation: closed-court extension cannot override the statutory three-month period and limited extra time.

Section 34(3) of the Arbitration and Conciliation Act prescribes a three-month limitation period to challenge an arbitral award, with a further thirty days available only on sufficient cause and not thereafter. The Court held that the exclusionary words in the provision displace the general closed-court extension under Section 4 of the Limitation Act for any filing beyond that statutory cap. For Section 4, the relevant "prescribed period" is the initial three months, not the additional discretionary thirty days. Accordingly, the vacation reopening of court could not extend time for an application filed after expiry of the three-month period.

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Issues: Whether Section 4 of the Limitation Act, 1963 applies to an application under Section 34 of the Arbitration and Conciliation Act, 1996 so as to extend the time for filing beyond the three-month period and the further thirty-day period prescribed therein when the court reopens after vacation.

Analysis: Section 34(3) of the Arbitration and Conciliation Act, 1996 prescribes a three-month period for moving an application to set aside an arbitral award, with a further period of thirty days available only on sufficient cause being shown and not thereafter. The Court reiterated that the phrase "but not thereafter" constitutes an express exclusion of the general limitation provisions to that extent. Reading Section 43(1) of the 1996 Act with Section 2(j) and Section 4 of the Limitation Act, 1963, the Court held that the "prescribed period" for the purpose of Section 4 is the three-month period, not the additional thirty days under the proviso to Section 34(3). Since the application was filed after expiry of the three months and the closed-court vacation could not enlarge the statutory cap, Section 4 was held inapplicable.

Conclusion: Section 4 of the Limitation Act, 1963 does not apply to extend the time for filing an application under Section 34 of the Arbitration and Conciliation Act, 1996 beyond the statutory three months and the further thirty days.

Ratio Decidendi: Where a special statute prescribes a limitation period with a further limited extension and uses exclusionary language such as "but not thereafter", the general closed-court extension under Section 4 of the Limitation Act, 1963 cannot be invoked beyond the period treated as the prescribed period by the special statute.

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