Bengal Chemist And Druggists ... vs Kalyan Chowdhury

The Supreme Court upheld the dismissal of an appeal by the National Company Law Appellate Tribunal, affirming that Section 421(3) of the Companies Act, 2013 establishes a strict limitation period of 45 days for filing appeals, with a further extension of 45 days only if sufficient cause is shown. The Court clarified that Section 5 of the Limitation Act, 1963 does not apply in this context due to the specific provisions of Section 421(3), which are peremptory in nature. The appeal was deemed not maintainable as the stipulated time limits had expired without sufficient cause being demonstrated.