Extension of limitation during COVID-19 was restored and made binding across courts and authorities.

In an extraordinary COVID-19 surge, the Supreme Court restored and continued the earlier extension of limitation periods to prevent hardship to litigants and legal practitioners, keeping the period of limitation under general and special laws extended for all judicial and quasi-judicial proceedings until further orders. It also continued the exclusion already operating for specified statutory limitation periods from 14.03.2021. Exercising powers under Article 142 read with Article 141 of the Constitution, the Court directed that the limitation-extension order would be binding on all Courts, Tribunals and Authorities.

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Issues: (i) Whether the earlier protection extending limitation periods in view of the COVID-19 pandemic should be restored and continued because of the renewed surge in cases. (ii) Whether the order extending limitation would operate as a binding direction on all Courts, Tribunals and Authorities.

Issue (i): Whether the earlier protection extending limitation periods in view of the COVID-19 pandemic should be restored and continued because of the renewed surge in cases.

Analysis: The renewed nationwide rise in COVID-19 cases was treated as an extraordinary situation requiring further relief to avoid hardship to litigants and legal practitioners. The earlier directions were restored, and the period of limitation under general and special laws for all judicial and quasi-judicial proceedings was directed to remain extended till further orders. The exclusion already operating for specified statutory limitation periods was also continued from 14.03.2021 till further orders.

Conclusion: The extension of limitation was restored and continued in favour of litigants.

Issue (ii): Whether the order extending limitation would operate as a binding direction on all Courts, Tribunals and Authorities.

Analysis: The direction was expressly issued in exercise of the Court's powers under Article 142 read with Article 141 of the Constitution of India. On that basis, the order was declared to be binding within the meaning of Article 141 on all Courts, Tribunals and Authorities.

Conclusion: The order was held to be binding on all Courts, Tribunals and Authorities.

Final Conclusion: The limitation-extension regime was revived and continued as a nation-wide measure, and the resulting directions were made binding across the judicial hierarchy and authorities.

Ratio Decidendi: In an extraordinary public emergency, the Court may invoke Article 142 to extend limitation periods and, when so issued, the direction attains binding force under Article 141.

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