Section 14 Limitation Act does not apply to criminal proceedings; delay condonation failed for lack of satisfactory explanation.

Section 14 of the Limitation Act, 1963 excludes time spent in bona fide prosecution before a court lacking jurisdiction, but the provision is confined to civil proceedings and cannot, by itself, be invoked in criminal matters. In criminal proceedings, exclusion of time is governed by the relevant criminal procedural provision, including Section 470(1) of the Code of Criminal Procedure, 1973. On the stated facts, the delay in filing the leave to appeal application was not satisfactorily explained, and the earlier attempt did not remove that defect. The refusal to condone the two-year delay was therefore upheld.

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Issues: Whether the benefit of Section 14 of the Limitation Act, 1963 could be invoked to exclude time in a criminal revision and justify condonation of a two-year delay in filing the leave to appeal application.

Analysis: Section 14 of the Limitation Act, 1963 embodies the principle of exclusion of time spent in bona fide prosecution before a court lacking jurisdiction, but its text is confined to civil proceedings. The provision may aid appeals or revisions arising from civil proceedings, yet it does not extend to criminal proceedings. For criminal matters, the relevant exclusion principle is found in Section 470(1) of the Code of Criminal Procedure, 1973. On the facts, the petitioner offered no satisfactory explanation for the substantial delay in first filing the leave to appeal application, and the earlier attempt did not cure that deficiency.

Conclusion: The benefit of Section 14 of the Limitation Act, 1963 was not available in the criminal revision, and the delay was not satisfactorily explained; the refusal to condone delay was upheld against the petitioner.

Ratio Decidendi: Section 14 of the Limitation Act, 1963 applies to civil proceedings and cannot, by itself, be invoked to exclude time in criminal proceedings; condonation of delay in such matters depends on the applicable criminal procedural provision and a satisfactory explanation for delay.

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