Limitation extension under Sabka Vishwas Scheme remained unresolved, with the earlier judgment only clarified on deadline applicability.

The Kerala HC considered whether the Supreme Court's suo motu limitation-extension directions applied to the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 payment deadline. It observed that the interaction between the general limitation directions and the scheme-specific due date required deeper analysis, and noted that the amount due had been remitted within three days of the last date under the Scheme. The earlier judgment was therefore not altered on merits; it was only clarified that the question whether the Supreme Court directions extended the Scheme deadline had not been finally adjudicated.

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Issues: Whether the directions issued by the Supreme Court in Suo Motu Writ Petition (C) No. 3 of 2020 extended the last date for payment under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019, and whether the earlier judgment required review on that question.

Analysis: The Court noted that the scope of the Supreme Court directions as to extension of limitation in relation to the Scheme's payment deadline required deeper analysis. It also recorded that, on the facts, the amount payable under the Scheme had been remitted within three days of the last date fixed in the Scheme. In that situation, the earlier judgment was not modified on merits, but only clarified to the extent that the issue whether the Supreme Court directions extended the Scheme deadline had not been finally adjudicated.

Conclusion: The review was not used to finally decide the question of extension of the Scheme deadline, and the prior judgment was retained with the above clarification.

Ratio Decidendi: Where the applicability of a general limitation-extension direction to a scheme-specific payment deadline requires deeper analysis, and the factual payment is substantially within time, the court may decline final adjudication on the broader legal question while issuing a limited review clarification.

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