Statutory arbitration under the National Highways Act is not governed by Article 137 limitation, the Court held.

Article 137 of the Limitation Act, 1963 was held inapplicable to an application for arbitration under Section 3-G(5) of the National Highways Act, 1956. The Court examined the statutory arbitration scheme under Sections 3-G(5) and 3-G(6) of the National Highways Act alongside Sections 2(4), 21 and 43 of the Arbitration and Conciliation Act, 1996, and concluded that Section 2(4) excludes the operation of Section 43 in statutory arbitrations governed by another enactment. As a result, the Limitation Act could not be imported to control the special mechanism under the National Highways Act, and a time-bar objection based on Article 137 was unsustainable.

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Issues: Whether Article 137 of the Limitation Act, 1963 applies to an application seeking arbitration under Section 3-G(5) of the National Highways Act, 1956.

Analysis: The dispute arose from applications for re-determination of compensation under the statutory arbitration mechanism in the National Highways Act, 1956. The Court examined the interaction between Section 3-G(5) and Section 3-G(6) of that Act, and the provisions of Sections 2(4), 21 and 43 of the Arbitration and Conciliation Act, 1996. It held that Section 2(4) excludes the application of Section 43 to statutory arbitrations under other enactments, and therefore the Limitation Act does not apply to such statutory arbitrations by virtue of Section 43. The Court also distinguished authorities dealing with contractual arbitrations and held that the special statutory scheme under the National Highways Act could not be controlled by Article 137 of the Limitation Act.

Conclusion: Article 137 of the Limitation Act, 1963 does not apply to an application for arbitration under Section 3-G(5) of the National Highways Act, 1956, and the rejection of the landowners' claims as time-barred was unsustainable.

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