Limitation for arbitral award challenges cannot be extended by court reopening where the statutory outer period has already expired.

A petition under Section 34 of the Arbitration and Conciliation Act filed on the first day after court reopening was held time-barred. The three-month limitation period for challenging an arbitral award is computed by excluding the date of receipt under Section 12(1) of the Limitation Act, and any further 30-day extension depends on sufficient cause. Section 4 of the Limitation Act applies only where the prescribed period expires on a court holiday; it does not extend the limitation period beyond the statutory outer limit under the proviso to Section 34(3). The petition was filed after that outer period had also expired, so the benefit of Section 4 was unavailable.

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Issues: Whether a petition under Section 34 of the Arbitration and Conciliation Act, 1996 filed on the first day after court reopening was within limitation and entitled to the benefit of Section 4 of the Limitation Act, 1963.

Analysis: The period of limitation for an application to set aside an arbitral award is three months from receipt of the award, with a further outer period of thirty days available only on sufficient cause being shown. In computing the three months, the date of receipt of the award is excluded under Section 12(1) of the Limitation Act, 1963. On that basis, the prescribed period ended before the court vacation began. Section 4 of the Limitation Act, 1963 applies only where the prescribed period expires on a day when the court is closed, and the proviso to Section 34(3) does not expand the prescribed period for that purpose. The petition was filed after the outer period had also expired.

Conclusion: The petition was barred by limitation and was not entitled to the benefit of Section 4 of the Limitation Act, 1963.

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