Special limitation under land acquisition law excludes Section 5, while time-exclusion provisions may still apply.

A special limitation period under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 provides sixty days from the award, with a further extension of up to sixty days on sufficient cause. Because this is a self-contained special law, Section 5 of the Limitation Act does not apply. However, Section 29(2) does not bar the operation of Sections 4, 12, 13 and 14, so time may still be excluded while computing limitation unless expressly prohibited. On the stated facts, the appeal remained time-barred even after applying those exclusion principles, and the delay explanation was inadequate.

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Issues: Whether the delay in filing the appeal under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 could be condoned under Section 5 of the Limitation Act, 1963, and whether the appeal was filed within the permissible period after applying the relevant provisions on exclusion of time.

Analysis: Section 74(1) prescribes a special limitation period of sixty days from the date of the award, with a further period not exceeding sixty days on sufficient cause being shown. The provision was held to be a special law with its own limitation structure, thereby excluding the operation of Section 5 of the Limitation Act. At the same time, the Court held that Section 29(2) of the Limitation Act does not exclude the application of Sections 4, 12, 13 and 14, and those provisions may be applied while computing the limitation period. On the facts, the appeal was still found to be belated even after considering the available exclusion principles, and the explanation for the delay was inadequate.

Conclusion: Section 5 of the Limitation Act is not applicable to an appeal under Section 74(1) of the 2013 Act, and the delay in this case was not condonable.

Ratio Decidendi: Where a special statute prescribes a self-contained appellate limitation period with a fixed outer extension, Section 5 of the Limitation Act stands excluded, though provisions excluding time such as Sections 4, 12, 13 and 14 may still apply unless expressly barred.

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