Substitution after death in appeal requires reasonable time and condonation of delay; long-delayed applications were rejected.

Section 72 of the Prevention of Money Laundering Act permits proceedings to continue after an appellant's death, but it does not remove the need to seek substitution within a reasonable time. The Tribunal applied the principles underlying Order 22 CPC and Article 120 of the Limitation Act to hold that a substitution application filed beyond three months must be supported by a condonation request showing sufficient cause. Where the delay extended from 122 days to several years and no condonation application was filed, the explanation offered was rejected, the substitution applications were held not maintainable, and the appeals consequently abated.

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Issues: Whether substitution of the deceased appellants by their legal heirs could be allowed when the applications were filed after a long delay without an application for condonation of delay, and whether the appeals could be continued under Section 72 of the Prevention of Money Laundering Act, 2002.

Analysis: Section 72 of the Prevention of Money Laundering Act, 2002 permits proceedings to continue on the death of an appellant, but it does not dispense with the requirement of taking steps for substitution within a reasonable time. The Tribunal held that though it is not strictly bound by the Code of Civil Procedure, the principles underlying Order 22 of the Code of Civil Procedure, 1908 and Article 120 of the Limitation Act, 1963 can be applied to regulate substitution and preserve the lis. An application for substitution filed beyond the reasonable period of three months must therefore be supported by an application for condonation of delay with sufficient explanation. In the present matter, the delay ranged from 122 days to several years, no condonation application was filed, and the oral explanation based on non-functioning of the Tribunal was not accepted.

Conclusion: The applications for substitution were not maintainable in the absence of condonation of delay and were rejected; consequently, the appeals abated and stood dismissed.

Ratio Decidendi: Even where the governing statute is silent on limitation, substitution of deceased parties must be sought within a reasonable time, and long-delay substitution applications require condonation on sufficient cause before the proceedings can be continued.

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