The Property Company (P) Ltd. v. Rohinten Daddy Mazda
Background
A shareholder inherited shares in 1990 but only sought registration in 2013; when the company refused, he appealed to the Company Law Board (CLB) 249 days late. The CLB excused the delay and ruled in his favour; the Calcutta High Court upheld it.
Decision Breakdown
The Supreme Court held that ordinary courts can excuse delay under the Limitation Act, but tribunals like the CLB cannot unless a law specifically grants that power, which, at the relevant time, it did not. The power to condone delay was only given to the CLB's successor (NCLT) from 1 June 2016, and could not apply retroactively to save an already time-barred appeal.
Lesson Learnt
Deadlines before specialised tribunals are often strict and cannot be assumed flexible the way a court might be: check the specific law before assuming "sufficient cause" will save a late filing.