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Limitation period as to filing of Suits

1.    The Suit must be filed within the period prescribed under the Schedule appended to Limitation Act, 1963. The limitation period, would depend upon the nature of Suit which is filed and the Reliefs which are claimed in the Suit.

2.    The right of a person, if he has any, must be exercised within reasonable time, or else his said right will be forfeited as a penalty for his neglect. Laws come to the assist of the vigilant and not to the sleepy, so said by Salmond in his Jurisprudence.

3.    The doctrine of limitation is based on broad consideration, in the words of Abbott, CJ, in the case of Battley versus Faulkner, “the Statutes of limitation was intended for relief and quiet of the defendant and to prevent persons from being harassed at a distant point of time, after the committing of the injury complained of.” Also when the evidence are lost by defendant with the passage of time, at the benefit of the Plaintiff.

4.    A period of three years has been prescribed for suits relating to accounts, contracts, and declarations and suits relating to movable properties.

5.    A period varying from 1 to 3 years has been prescribed for suits relating to torts and miscellaneous maters.

6.    A period of twelve years has been prescribed for suits relating to recovery of Immovable properties, based on previous possession.

7.    And, in fact, there is no limitation period to recover possession of an immovable property, the claim which is based on title or any other interest. In these kind of Suits, the question of limitation of 12 years arises only when the Defendant takes the defense of being in possession of the concerned immovable property, for the last 12 years, immediately preceding the date of the filing of the Suit, and the Defendant claims that he was holding the possession of the property against the wishes and adverse to the interest of the Plaintiffs. If the Plaintiffs maintain in the Suit that the possession of the Defendant is permissive in nature, then, plea of adverse possession may not be available to the Defendant, and thereby the limitation period of 12 years as prescribed under Article 65 of Limitation Act does not come into play.

8.    A person who claim adverse possession has to prove that he has remained in uninterrupted possession of the property to the knowledge of the true owner and he has, expressly or by necessary implication, denied the title of the true owner and asserted his own right of ownership in the property to the exclusion of the true owner. Unless the occupation / possession of the defendant is permissive, expressly or impliedly, the occupation of the defendant shall deemed to be detrimental or adverse to the interest of the Plaintiffs.

9.    The extension of limitation period
Where it appears that the debt to be recovered is time barred by reason of lapse of time, it may be checked whether any payment was made in partial discharge of liability, the liability which is the subject matter of the Suit. If yes, and if by cheque, the details thereof. And if by cash, the details thereof. This part payment may extend the period of limitation by virtue of provisions of Section 18 of Limitation Act, 1963.

When the recovery of a debt appears to be frustrated due to lapse of time, recourse may be to sections 18 and 19 of limitation Act, 1963, apart from other provisions of Limitation Act. Sections 59, 60 and 61 of Contract Act, 1872 are also very relevant sections; and by a careful application of these sections, the apparently time barred debts may be brought within limitation period.

Section 18 of Limitation Act: An acknowledgement of liability extends the period of limitation and starts a fresh limitation period. An acknowledgement within the meaning of this section must have the following essential attributes –
a)    The acknowledgement must be an affirmative admission of an existing liability;
b)    It must be made by the person under the liability or by a person authorized to acknowledge;
c)    The liability must be subsisting on the date of the acknowledgement;
d)    The acknowledgement need not be made to the creditor;
e)    The acknowledgement may not indicate the precise amount of debt / liability; it is sufficient if the debtor acknowledges that something is due or may be due;
f)     The acknowledgement must be in writing and signed;
g)    The acknowledgement must be signed either by the debtor himself or by the agent duly authorized in that behalf;
h)    An acknowledgement of liability need not be in respect of debt only; it may be in respect of any property or right which is the subject matter of the suit;
i)      An absence of denial to a demand made does not operate as an acknowledgement;
j)      An acknowledgement by an agent is a valid acknowledgement to bind his principal;
k)    Acknowledgment of liability in the Balance Sheet is a valid acknowledgement of debt [Please see Section 138(b) of Income Tax Act, 1961];
l)      The acknowledgement need not directly refer to the liability sought to be enforced in the suit;
m)  An acknowledgement accompanied by refusal to pay is a valid acknowledgement within the meaning of this section;
n)    There may not be a promise to pay and mere acknowledgement of debt is sufficient to constitute Acknowledgement within the meaning of this section, thereby giving the fresh period of limitation to the creditor.

S. 19 of Limitation Act: Effect of payment on account of debt or of Interest on legacy
Where payment on account of a debt or of interest on a legacy is made before the expiration of the prescribed period by the person liable to pay the debt or legacy or by his agent duly authorized in this behalf, a fresh period of limitation shall be computed from the time when the payment was made:

S.22 of Limitation Act: Continuous cause of action: disturbance of right of worship is a continuous wrong; An infringement of Trade mark is a continuous wrong. A trespass upon the property is a continuous wrong.

Law of limitation only bars the remedy but does not extinguish the right. See contract Act 1872 section 26. of Limitation Act.

10.  The limitation period always starts from the date on which the cause of action arise, and therefore, it is very important to ascertain as on which date the cause of action arose.

11.  What is the date on which the cause of action arises: The cause of action arises on the date on which the aggrieved has a right to move the court of law or to adopt any legal proceedings, for redressal of his grievance, although the aggrieved person may choose not to move the court of law or to adopt any legal proceedings, immediately, and he may prefer to redress his / her grievance by resorting to any other legal means, including recording / interacting with the concerned manufacturer / supplier of goods or services who have allegedly supplied defective goods / or have rendered deficient services, etc.

12.  The period to file Suit ends according to the applicable nature of Suit which is filed and the Reliefs which are claimed in the Suit.

13.  The applicable Article of the Limitation Act, 1963, may be stated so as to compute the limitation period.] If the Suit is filed beyond limitation, then, a statement showing the grounds on which the exemption from the law of limitation is claimed [Sections 6, 7, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23]. Please read further at link below

Sandeep Jalan
Advocate


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