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Issues: Whether the benefit of Section 4 of the Limitation Act, 1963 or Section 10 of the General Clauses Act, 1897 is available where the three-month period under Section 34(3) of the Arbitration and Conciliation Act, 1996 has expired and the additional thirty-day condonable period ends during court vacation.
Analysis: Section 34(3) prescribes a three-month period for challenging an arbitral award, with a further thirty days available only on sufficient cause and not thereafter. The expression "prescribed period" in Section 2(j) of the Limitation Act refers to the period of limitation, and the additional thirty-day period in the proviso is not part of that prescribed period. Section 4 of the Limitation Act therefore applies only when the last day of the three-month period falls on a day when the court is closed, not to the discretionary condonable period. The application of the Limitation Act to arbitration proceedings, read with the express limitation in Section 34(3), also excludes reliance on Section 10 of the General Clauses Act, 1897 for extending the condonable period.
Conclusion: The benefit of Section 4 of the Limitation Act and Section 10 of the General Clauses Act is not available for filing an application after expiry of the three-month period when the delayed filing falls within the additional condonable thirty days that end during court vacation.
Ratio Decidendi: In proceedings under Section 34(3) of the Arbitration and Conciliation Act, 1996, only the three-month limitation period is the "prescribed period"; the further thirty-day condonable period is discretionary and cannot be extended by Section 4 of the Limitation Act, 1963 or Section 10 of the General Clauses Act, 1897.