Arbitral award challenge limitation is self-contained; Section 17 of the Limitation Act does not extend the statutory deadline.

Section 17 of the Limitation Act, 1963 does not postpone limitation for an application to set aside an arbitral award under Section 34(3) of the Arbitration and Conciliation Act, 1996. Section 34(3) is a self-contained limitation code: time runs from receipt of the award, and condonation is confined to the statutory three-month period plus a further thirty days. Reading Section 17 into that scheme would alter the starting point of limitation, conflict with the phrase "but not thereafter", and undermine finality and speedy enforcement of arbitral awards.

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Issues: Whether Section 17 of the Limitation Act, 1963 applies to postpone the limitation period for filing an application to set aside an arbitral award under Section 34(3) of the Arbitration and Conciliation Act, 1996.

Analysis: Section 29(2) of the Limitation Act, 1963 makes Sections 4 to 24 applicable to a special law only to the extent they are not expressly excluded. Section 34(3) of the Arbitration and Conciliation Act, 1996 prescribes a complete and self-contained limitation scheme for challenges to arbitral awards, fixing the starting point from receipt of the award and permitting condonation only up to thirty days beyond the initial three months. Applying Section 17 would shift the commencement of limitation from receipt of the award to discovery of fraud or mistake, thereby defeating the phrase "but not thereafter", unsettling the enforcement mechanism under Section 36, and undermining the statutory objective of finality and speedy resolution.

Conclusion: Section 17 of the Limitation Act, 1963 does not apply to an application under Section 34(3) of the Arbitration and Conciliation Act, 1996. The delay could not be condoned beyond the statutory outer limit, and the remand order and the condonation order were liable to be set aside.

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