Strict limitation under the NIA Act bars delayed appeals beyond the outer period and excludes condonation under Section 5.

An appeal under Section 21 of the National Investigation Agency Act, 2008 could not be entertained after the expiry of the outer limit of ninety days, because the second proviso was treated as an express exclusion of Section 5 of the Limitation Act, 1963. Applying Section 29(2), the Court held that the general condonation provision in Sections 4 to 24 applies to special laws only where not expressly excluded, and the structure and object of Section 21 showed a strict limitation scheme. Section 12 of the Limitation Act was not excluded, but that did not preserve an appeal filed beyond the permissible period. The delay-condonation application was therefore not maintainable.

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Issues: Whether an appeal under Section 21 of the National Investigation Agency Act, 2008 could be entertained after expiry of ninety days and whether Section 5 of the Limitation Act, 1963 applied to condone the delay.

Analysis: The appeal under the special statute lay to the High Court and the limitation scheme in Section 21 fixed thirty days, permitted condonation for sufficient cause up to ninety days, and then stated that no appeal shall be entertained thereafter. Applying Section 29(2) of the Limitation Act, 1963, the Court held that provisions in Sections 4 to 24 apply to special laws only to the extent they are not expressly excluded. The structure of Section 21, especially the second proviso, was treated as an express exclusion of Section 5. The Court also noted that the object and scheme of the Act supported a strict limitation regime and that Section 12 of the Limitation Act, 1963 was not excluded, though that did not save an appeal filed beyond the outer limit.

Conclusion: Section 5 of the Limitation Act, 1963 was held inapplicable and the delay-condonation application was not maintainable.

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