Case Brief Compilation on Section 14 — Limitation Act, 1963

 

📚 Case Brief Compilation on Section 14 — Limitation Act, 1963

---

1️⃣ Roshan Lal v. R.B. Mohan Singh Oberoi

Citation: AIR 1975 SC 824
Court: Supreme Court of India

✅ Facts: Suit filed in a wrong court; issue arose whether Section 14 could be invoked.
✅ Held: Section 14 is not restricted only to cases of lack of jurisdiction but extends to any similar causes where the court is unable to entertain the matter.
✅ Key Principle: Liberal interpretation to promote justice; section applies to similar procedural defects, not just formal jurisdictional errors.

---

2️⃣ Union of India v. West Coast Paper Mills Ltd.

Citation: AIR 2004 SC 1596
Court: Supreme Court of India

✅ Facts: Proceeding before a tribunal failed due to lack of authority; fresh action filed.
✅ Held: Section 14 applies to civil proceedings before tribunals or quasi-judicial bodies, not only civil courts.
✅ Key Principle: Broad scope; covers non-court civil proceedings if pursued bona fide and diligently.

---

3️⃣ Consolidated Engineering Enterprises v. Principal Secretary, Irrigation Dept.

Citation: (2008) 7 SCC 169
Court: Supreme Court of India

✅ Facts: Delay in filing under Arbitration Act; sought exclusion under Section 14.
✅ Held: Section 14 applies to arbitration-related applications as they are civil in nature.
✅ Key Principle: The term “civil proceedings” under Section 14 includes arbitration matters.

---

4️⃣ M.P. Steel Corporation v. Commissioner of Central Excise

Citation: (2015) 7 SCC 58
Court: Supreme Court of India

✅ Facts: Party sought exclusion of time spent in a wrong forum.
✅ Held: Section 14 protects only those who acted with due diligence and good faith; negligent or careless parties cannot claim benefit.
✅ Key Principle: Essential elements are good faith and due diligence.

---

5️⃣ Krishna v. Chathappan

Citation: (1889) ILR 13 Mad 269 (FB)
Court: Madras High Court (Full Bench)

✅ Facts: Old foundational case on limitation principles.
✅ Held: Limitation statutes must be strictly construed, but equitable sections like Section 14 should be used to prevent injustice.
✅ Key Principle: Early recognition of equity balancing strict limitation rules.

---

---

✨ Quick Summary

Element	Requirement
Scope	Civil proceedings, including tribunals, arbitration
Key Conditions	Good faith + due diligence
Applies To	Lack of jurisdiction or similar procedural defect
Interpretation	Liberal, to advance cause of justice
Not Covered	Cases decided on merits or party negligence