Section 14 of the Limitation Act Applies to Arbitration and Conciliation Act Proceedings : Supreme Court
In Kirpal Singh Vs Government of India, the Supreme Court ruled that Section 14 of the Limitation Act, 1963 applies to the Arbitration and Conciliation Act, 1996. Section 14 excludes the time spent pursuing proceedings in a wrong forum from the limitation period. A bench of Justices PS Narasimha and Manoj Misra emphasized a liberal interpretation of the Limitation Act due to the narrow timeframe for challenging an arbitral award.
In this case, the appellant initially filed an appeal against the arbitral award in the High Court, later realizing that the correct remedy was to appeal under Section 34 of the Arbitration Act in the District Court. The District Court dismissed the appeal as time-barred, refusing to exclude the time spent in the wrong forum.
The Supreme Court referenced the 2008 Consolidated Engineering Enterprises judgment and held that the limitation provisions must be interpreted liberally to preserve the right to challenge an arbitral award. Consequently, the Court ruled that the appeal before the District Court was within the limitation period, applying Section 14.