Section 24(1)(a) and limitation principles govern pending land acquisition appeals under the 2013 Act, with delay condonable.

Section 24(1)(a) of the 2013 land acquisition law applies where proceedings under the 1894 Act had commenced but no award was made before the 2013 Act came into force, so the award stage is governed by the 2013 Act while rehabilitation and resettlement entitlements are not retrospectively imported. An appeal under Section 74 is not excluded from the Limitation Act because the 2013 Act does not expressly bar it and Section 29(2) preserves Section 5. Delay in filing first appeals may therefore be considered on the basis of sufficient cause, and the High Court's refusal to condone delay was set aside.

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Issues: (i) Whether land acquisition proceedings initiated under the Land Acquisition Act, 1894, but culminating in an award after commencement of the 2013 Act, are governed by Section 24(1)(a) of the 2013 Act. (ii) Whether an appeal under Section 74 of the 2013 Act is subject to Section 5 of the Limitation Act, 1963. (iii) Whether the delay in filing the first appeals deserved condonation.

Issue (i): Whether land acquisition proceedings initiated under the Land Acquisition Act, 1894, but culminating in an award after commencement of the 2013 Act, are governed by Section 24(1)(a) of the 2013 Act.

Analysis: Section 24(1)(a) applies where acquisition proceedings under the 1894 Act had commenced but no award had been made before commencement of the 2013 Act. In such cases, the acquisition continues, but the award-making stage is governed by the 2013 Act, save that rehabilitation and resettlement entitlements are not retrospectively imported into proceedings initiated under the earlier Act. The provision is a savings clause designed to extend the beneficial regime of the 2013 Act to pending matters at the stage of compensation determination.

Conclusion: The proceedings were correctly treated as governed by Section 24(1)(a) of the 2013 Act, and the awards had to be made under the 2013 Act, apart from rehabilitation and resettlement entitlements.

Issue (ii): Whether an appeal under Section 74 of the 2013 Act is subject to Section 5 of the Limitation Act, 1963.

Analysis: Section 74 prescribes a limitation period for appeals to the High Court, and its proviso only permits a further period within which the delayed appeal may still be entertained. The 2013 Act does not expressly exclude the Limitation Act, and Section 103 states that the Act is in addition to and not in derogation of other laws in force. Read with Section 29(2) of the Limitation Act, 1963, the absence of express exclusion means that Section 5 remains available. The statutory scheme does not justify reading an implied exclusion into Section 74.

Conclusion: Section 5 of the Limitation Act, 1963 applies to appeals under Section 74 of the 2013 Act.

Issue (iii): Whether the delay in filing the first appeals deserved condonation.

Analysis: Since Section 5 of the Limitation Act, 1963 applied, and the matters involved appeals against awards under the 2013 Act, the delay applications were liable to be considered on the liberal standard of sufficient cause. The Court found no reason to remit the matters for further delay adjudication and preferred to avoid prolonging the litigation.

Conclusion: The delay in filing the first appeals was condoned and the applications were allowed.

Final Conclusion: The impugned High Court orders were set aside to the extent they had rejected condonation, and the first appeals were permitted to proceed on merits under the 2013 Act regime.

Ratio Decidendi: Where a special statute prescribing a limitation period does not expressly exclude the Limitation Act, 1963, Section 5 remains applicable by virtue of Section 29(2); and for pending land acquisition proceedings culminating in an award after commencement of the 2013 Act, Section 24(1)(a) requires application of the 2013 Act at the award stage.

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