Condonation of delay is procedural; amended limitation law applied, and the time-bar dismissal was sustained.

Condonation of delay is procedural, so no vested right survives to seek unlimited extension under the earlier regime. An appeal arising under the Foreign Exchange Regulation Act was governed by the law in force on the date of the order and appeal, not the law when proceedings began; accordingly, the amended provision limiting condonation to a further 45 days applied. The plea of vested right was rejected and the time-bar dismissal was sustained.

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Issues: Whether the appellant had a vested right to seek condonation of delay under the unamended provision, or whether the amended law restricting condonation to a further period of 45 days governed the appeal.

Analysis: The appeal arose under Section 54 of the Foreign Exchange Regulation Act, 1973. The Court noted that the proceedings were initiated under the unamended provisions, but the order-in-original and the appeal were governed by the law in force on the date of the order. It held that the law relating to condonation of delay is procedural in character and therefore no vested right survives to claim unlimited condonation under the earlier provision. On that basis, the amended Section 52(2) of the Act, which limits condonation to 45 days beyond the prescribed period, applied to the appeal.

Conclusion: The plea of vested right was rejected and the dismissal of the appeal as time-barred was sustained.

Ratio Decidendi: The law governing condonation of delay is procedural, and the limitation regime in force on the date of the order or appeal applies, not the one prevailing when the proceedings were initiated.

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