Statutory limitation in customs appeals cannot be extended beyond the outer limit, though writ relief may restore merits review.

A statutory customs appellate authority cannot entertain an appeal once the prescribed limitation period and the limited condonable extension have expired, because it lacks jurisdiction to enlarge time by equitable or inherent powers. The rejection of time-barred appeals was therefore legally sustainable. However, in exceptional cases, the High Court may invoke Article 226 to grant conditional relief where delay is not deliberate or mala fide and the dispute has not been examined on merits. On that basis, the Court restored the appeals to the appellate stage for fresh adjudication, while leaving the statutory limitation scheme intact.

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Issues: (i) whether the appellate authorities were justified in rejecting the appeals as time-barred under the statutory limitation scheme governing customs appeals; (ii) whether the High Court could, in exercise of writ jurisdiction, condone the delay and restore the appeals for decision on merits.

Issue (i): Whether the appellate authorities were justified in rejecting the appeals as time-barred under the statutory limitation scheme governing customs appeals.

Analysis: The appeals were filed beyond the period prescribed for filing a customs appeal, and the statute permits condonation only within the further limited period expressly provided. Once that outer limit expires, the appellate authority lacks jurisdiction to entertain the appeal or extend limitation by invoking equitable or inherent powers. The rejection of the appeals on limitation, therefore, accorded with the statutory scheme.

Conclusion: The rejection of the appeals by the appellate authorities on the ground of limitation was legally sustainable.

Issue (ii): Whether the High Court could, in exercise of writ jurisdiction, condone the delay and restore the appeals for decision on merits.

Analysis: Although the statutory authorities could not go beyond the prescribed limitation, the High Court held that its constitutional jurisdiction under Article 226 could be invoked in appropriate cases to prevent technicalities from defeating substantive justice. The delay, though beyond the condonable period, was not found to be deliberate or mala fide, and the underlying dispute had not been examined on merits by the appellate authority. To avoid foreclosing the statutory remedy altogether, the Court intervened and granted conditional relief by restoring the matter to the appellate stage.

Conclusion: The High Court was competent to grant conditional writ relief, condone the delay, and remit the appeals for fresh adjudication on merits.

Final Conclusion: The writ petition succeeded only to the extent of securing restoration of the appeals after conditional condonation of delay, while the statutory position on limitation remained undisturbed.

Ratio Decidendi: A statutory appellate authority cannot condone delay beyond the outer limit expressly fixed by the statute, but the High Court may, in exceptional cases under Article 226 of the Constitution of India, grant conditional relief to prevent denial of substantive justice and restore the matter for merits-based adjudication.

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