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Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering — with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Company & Insolvency LawSupreme Court

Regional Provident Fund Commissioner-II v. Mamta Binani & Ors.

Civil Appeal · 2026 INSC 1003Decided 10 Sept 2026

Civil Appeal arising out of Diary No. 42931 of 2026

Justice Dipankar Datta · Justice Sheel Nagu

Background

The NCLT approved a resolution plan for Rolta India Limited on 15 December 2025. The Regional Provident Fund Commissioner, aggrieved by this approval, tried to e-file an appeal before the NCLAT starting from 28 January 2026, one day before the outer condonable limit (30 days + 15 days grace) under Section 61(2) of the IBC expired, but the NCLAT's own e-filing portal suffered a technical/OTP glitch that prevented filing on both 28 and 29 January. The appeal was finally e-filed on 30 January 2026, one day beyond the maximum permissible period, and the NCLAT dismissed the condonation application and the appeal itself as time-barred, holding it had no power to condone delay beyond the statutory 45-day outer limit.

Decision Breakdown

The Supreme Court agreed that the NCLAT correctly read Section 61(2) as allowing no condonation beyond 45 days, and that its own precedents (National Spot Exchange, Tata Steel) were correctly stated but factually distinguishable since those cases involved litigant fault, not tribunal system failure. Here, the delay was caused entirely by a backend/OTP failure in the NCLAT's own e-filing system, as confirmed by the NCLAT Registry's own report. Invoking the principle "actus curiae neminem gravabit" (an act of the court shall harm no one), the Court held that limitation runs against a litigant only when the court/tribunal's own systems are actually capable of receiving filings; when the tribunal's system itself fails, the litigant should not be penalised. It set aside the NCLAT's order and restored the appeal for fresh consideration, directing that the date of the first bona fide e-filing attempt be treated as the date of presentation.

Lesson Learnt

Even a rigid statutory limitation deadline cannot be used to shut a litigant out when the delay is proven to be caused by a failure of the court or tribunal's own filing system, not the litigant's fault. Courts can exempt such periods from limitation computation under the "actus curiae neminem gravabit" principle.

Regional Provident Fund Commissioner-II v. Mamta Binani & Ors. – Legal Case Shots | LegalAware