Belated payment under legacy dispute settlement scheme treated as valid where timelines were held directory and declaration was accepted.

Under the Sabka Vishwas Legacy Dispute Resolution Scheme, a declaration had been accepted and Form SVLDRS-3 issued, but the payment was remitted after the original and extended timelines during the pandemic. The Court treated the belated remittance as payment under the Scheme because the amount was quantified under the accepted form and the Department had received it. It further held that the Scheme's payment timeline was directory, not mandatory, since the statutory design allowed the Central Government to extend time by notification and the pandemic context supported a liberal construction. The petitioner was therefore entitled to the Scheme benefit and discharge certificate.

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Issues: (i) Whether the payment made after the original and extended timelines under the Sabka Vishwas Legacy Dispute Resolution Scheme could still be treated as payment under the Scheme; (ii) Whether the time prescription for payment under the Scheme was mandatory or directory.

Issue (i): Whether the payment made after the original and extended timelines under the Sabka Vishwas Legacy Dispute Resolution Scheme could still be treated as payment under the Scheme?

Analysis: The declaration under the Scheme had been accepted and Form SVLDRS-3 had already been issued. The amount determined under that form was remitted during the pandemic period, and the Court noted that the Scheme had been extended from time to time through notifications in view of the prevailing situation. The payment, though made beyond the originally stipulated date, was linked to the quantified amount under the Scheme and had been accepted by the Department.

Conclusion: The payment made by the petitioner was to be treated as payment under the Scheme, and the Department was bound to issue the discharge certificate.

Issue (ii): Whether the time prescription for payment under the Scheme was mandatory or directory?

Analysis: The Court held that the statutory design of the Scheme vested power in the Central Government to fix and extend the time limits by notification, which indicated that the time prescription was not rigidly mandatory. The pandemic situation and the Supreme Court's extension of limitation periods were treated as relevant circumstances supporting a liberal construction of the Scheme's timelines.

Conclusion: The time limit for payment under the Scheme was held to be directory, not mandatory.

Final Conclusion: The petitioner was entitled to the benefit of the Scheme on the facts found, and the respondents were directed to recognise the payment and complete the discharge process.

Ratio Decidendi: Where a statutory settlement scheme empowers the authority to extend payment timelines by notification and the declaration has already been accepted, the time prescription may be construed as directory, permitting acceptance of belated payment made during extraordinary circumstances such as a pandemic.

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