M/S NORTH EASTERN CHEMICALS INDUSTRIES (P)LTD. vs M/S ASHOK PAPER MILL ( ASSAM) LTD

The Supreme Court examined whether Article 116 of the Limitation Act, 1963, applies to proceedings under the Jogighopa (Assam) Unit of Ashok Paper Mills Limited (Acquisition Transfer of Undertaking) Act, 1990, and whether an appeal filed after nearly three years from the order is maintainable in the absence of specific limitation provisions in the statute. The Court analyzed the applicability of general limitation laws to special statutes and the timeliness of appeals in such contexts. It upheld that the limitation period under Article 116 does not apply, and the appeal filed after a significant delay was maintainable, emphasizing the importance of statutory provisions over general law in such cases.