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Issues: Whether the delay in filing the Section 34 petition beyond the prescribed period could be condoned on the ground that the court was closed during vacation and the filing was made on the next working day, and whether the delay application disclosed sufficient cause.
Analysis: The proviso to Section 34(3) of the Arbitration and Conciliation Act, 1996 prescribes three months as the limitation period and permits condonation of delay only up to thirty days thereafter, with the expression "but not thereafter" making the cap mandatory. The benefit of Section 10 of the General Clauses Act, 1897 and Section 4 of the Limitation Act, 1963 applies only where the prescribed period expires on a day when the court is closed, and does not extend the separate condonable period of thirty days. The Court held that the affidavit seeking condonation was vague and perfunctory, with no adequate explanation of what prevented filing within the three months or during the period before vacation commenced. The scheme of the Arbitration and Conciliation Act, 1996 also requires strict adherence to timelines because of the finality of arbitral awards and limited judicial intervention.
Conclusion: The delay was not condonable and the application for condonation failed.
Final Conclusion: The challenge to the arbitral award could not be entertained as the Section 34 petition was time barred, and the petition was rejected on limitation.
Ratio Decidendi: The statutory extension for a court holiday applies only to the prescribed limitation period and not to the further condonable period under the proviso to Section 34(3); delay beyond thirty days after expiry of three months cannot be condoned.