Government suits under the Limitation Act follow the special thirty-year period, not the general limitation articles, and this suit was timely.

A suit by or on behalf of the Government is governed by the special limitation period in Article 112 of the Limitation Act, 1963, which overrides the general periods in Articles 58 and 100. Because the Government's declaratory suit challenged the Tax Recovery Officer's order and was filed within thirty years from that order, it was within time. The Court therefore treated Article 112 as the controlling provision for Government suits of this nature and held the suit not barred by limitation.

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Issues: Whether a suit by the Central Government challenging the Tax Recovery Officer's order and asserting that the attached property belonged to the debtor was governed by Article 112 of the Limitation Act, 1963 or by the shorter limitation periods in Articles 58 or 100.

Analysis: The suit was instituted by the Central Government to set aside the Tax Recovery Officer's order made in proceedings initiated under section 222 of the Income-tax Act, 1961. Article 112 prescribes a special and longer limitation period for suits by or on behalf of the Government, reflecting the legislative policy that the State is not to be placed on the same footing as a private litigant. Articles 58 and 100 are general provisions, whereas Article 112 is a specific provision governing suits of this nature by the Government. The period therefore commenced from the date of the Tax Recovery Officer's order, and the suit filed within thirty years was within time.

Conclusion: The suit was held to be governed by Article 112 of the Limitation Act, 1963 and not by Articles 58 or 100; it was within limitation.

Final Conclusion: The appeal failed and the dismissal followed because the Government's declaratory suit was timely under the special limitation provision applicable to it.

Ratio Decidendi: In a suit by or on behalf of the Government, a special limitation article applicable to such suits overrides general limitation articles, and the suit must be tested by the special period prescribed for Government actions.

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