KAUSHALYA RANI vs GOPAL SINGH

The Supreme Court held that the provisions of Section 417(4) of the Code of Criminal Procedure constitute a special law of limitation governing appeals by private prosecutors, and therefore, Section 5 of the Limitation Act (9 of 1908) does not apply. The Court clarified that a special law is enacted for specific cases and circumstances, contrasting with the general rules of limitation. The appeal was dismissed as the application for special leave was filed beyond the prescribed time limit.