Special limitation under land acquisition law excludes further condonation beyond the statutory outer limit for appeals.

A special statute prescribing an appeal period under Section 74 of the 2013 land acquisition law was treated as having its own limitation regime, so Section 29(2) of the Limitation Act did not prevent that statute from operating as special law for limitation purposes. The proviso allowing a further period of sixty days on sufficient cause was held to be an express exclusion of Section 5 of the Limitation Act beyond the outer limit. Once that statutory limit expired, delay could not be condoned and the appeal became time-barred.

---

---

Issues: (i) Whether the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is a general law so that Section 29(2) of the Limitation Act, 1963 does not apply to appeals under Section 74; (ii) Whether Section 5 of the Limitation Act, 1963 can be invoked to condone delay in filing an appeal under Section 74(1) of the 2013 Act beyond the further period of sixty days prescribed in its proviso.

Issue (i): Whether the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 is a general law so that Section 29(2) of the Limitation Act, 1963 does not apply to appeals under Section 74.

Analysis: The classification of a statute as general or special depends on the context and the subject under consideration. Even if the 2013 Act is a general law in relation to land acquisition, it becomes a special law when it prescribes a distinct limitation regime for appeals under Section 74. The court rejected the contention that the 2013 Act's general character excluded Section 29(2) altogether.

Conclusion: The contention was rejected. For limitation purposes under Section 74, the 2013 Act operates as a special law.

Issue (ii): Whether Section 5 of the Limitation Act, 1963 can be invoked to condone delay in filing an appeal under Section 74(1) of the 2013 Act beyond the further period of sixty days prescribed in its proviso.

Analysis: Section 74(1) allows an appeal within sixty days and the proviso permits filing within a further period not exceeding sixty days on sufficient cause being shown. That structure was held to be an express exclusion of Section 5 of the Limitation Act, 1963. The statutory phrase "not exceeding sixty days" was treated as the outer limit, and permitting any further condonation would render those words otiose. The court relied on the scheme of Section 74 and authorities construing similar limitation provisions in special statutes.

Conclusion: Section 5 of the Limitation Act, 1963 is inapplicable beyond the total period of 120 days. The delay could not be condoned.

Final Conclusion: The delay applications failed because the appellate remedy under Section 74 is confined to the statutory outer limit, after which the High Court lacks power to extend time. The appeals, being time-barred beyond that limit, could not be entertained.

Ratio Decidendi: Where a special statute prescribes an appeal within a fixed period and then allows condonation only up to a further specified period by using limiting words such as "not exceeding", the legislature is taken to have expressly excluded Section 5 of the Limitation Act, 1963 beyond that outer limit.

---