IBC appeal limitation runs from the order date; free certified copy rules do not suspend time or revive delay.

Limitation for appeals under the Insolvency and Bankruptcy Code runs from the order date, subject only to statutory exclusion for time requisite to obtain a copy; it is not deferred until receipt of a free certified copy under tribunal rules. Rule 50 is procedural and does not suspend limitation, while Section 12 of the Limitation Act applies only to copy-obtaining time. The Supreme Court's COVID-19 limitation exclusions did not cure delay already running before 15.03.2020, so the pre-pandemic delay had to be explained separately. On these principles, the appeals were treated as time-barred.

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Issues: (i) Whether the period from 15.03.2020 to 02.10.2021 excluded by the Supreme Court's COVID-19 limitation orders could save the appeals from limitation. (ii) Whether, under Section 61 of the Insolvency and Bankruptcy Code, 2016 read with Rule 50 of the National Company Law Tribunal Rules, 2016, limitation for filing the appeals could be deferred until a free certified copy of the order was received.

Issue (i): Whether the period from 15.03.2020 to 02.10.2021 excluded by the Supreme Court's COVID-19 limitation orders could save the appeals from limitation.

Analysis: The relevant impugned order was passed on 20.07.2018, which was much before the commencement of the excluded COVID period. The exclusion directed by the Supreme Court assisted only in computing limitation within that specified period and did not wipe out the delay that had already run between the date of the impugned order and 14.03.2020. The appellant was therefore required to explain the pre-15.03.2020 delay, which was not done.

Conclusion: The COVID-19 limitation exclusion did not make the appeals timely and does not assist the appellant.

Issue (ii): Whether, under Section 61 of the Insolvency and Bankruptcy Code, 2016 read with Rule 50 of the National Company Law Tribunal Rules, 2016, limitation for filing the appeals could be deferred until a free certified copy of the order was received.

Analysis: Section 61 prescribes a 30-day filing period, extendable by a further 15 days, and omits the language found in the Companies Act regime that tied limitation to the order being made available. Rule 50 is procedural and obliges the Registry to send a free copy, but it does not suspend limitation. The scheme of the Insolvency and Bankruptcy Code is time-bound, and Section 12 of the Limitation Act, 1963 governs only exclusion of time requisite for obtaining a copy, not postponement of commencement until a free copy is received. The appellant's reliance on earlier authority did not help because, on the facts, the certified copy was sought after an inordinate delay and the later Supreme Court decision on the IBC governed the issue.

Conclusion: Limitation under Section 61 did not wait for receipt of a free certified copy, and the appeals were barred by limitation.

Final Conclusion: The appeals were held to be time-barred and were not entertained.

Ratio Decidendi: Under Section 61 of the Insolvency and Bankruptcy Code, 2016, limitation for appeal runs from the order date subject only to the statutory exclusion for time requisite to obtain a copy, and it is not suspended until a free certified copy is received under the tribunal rules.

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