Kirpal Singh Vs. Government of India, New Delhi & Ors

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In Kirpal Singh v. Government of India, New Delhi & Ors, the Supreme Court condoned a 126-day delay in filing an application under Section 34 of the Arbitration and Conciliation Act, holding that Section 14 of the Limitation Act, which excludes time spent before courts without jurisdiction, applies to Section 34. The appellant initially filed a regular first appeal before the High Court, but upon recognizing the proper remedy under Section 34, approached the District Court on 23.02.2012, where the application was dismissed as time-barred. The apex court, relying on Consolidated Engineering Enterprises v. Principal Secretary, 2008 (7) SCC 169, reaffirmed that the Arbitration Act does not exclude Section 14 of the Limitation Act and emphasized a liberal interpretation of limitation provisions to ensure access to statutory remedies under Sections 34 and 37. Consequently, the Court allowed the appellant’s challenge to the arbitral award.

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