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Issues: Whether an application under Section 20 of the Arbitration Act was governed by Article 137 of the Limitation Act, 1963, and whether the application was time-barred.
Analysis: The Court applied the settled position that Article 137 of the Limitation Act, 1963 applies to applications presented to a Civil Court under any Act, including an application under Section 20 of the Arbitration Act. On the facts, the right to apply arose when the final bill was passed and the no claim certificate was issued, and the application was filed more than three years thereafter.
Conclusion: Article 137 applied, and the application under Section 20 was barred by limitation.