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Supreme Court of India 2019-09-18 allowed

GAURAV HARGOVINDBHAI DAVE vs ASSET RECONSTRUCTION COMPANY (INDIA) LTD

Bench: 3 — Rohinton Fali Nariman, R. Subhash Reddy, Surya Kant

In Brief

A creditor bank assigned a defaulted debt of ₹50 crores to an ARC, which filed a Section 7 insolvency application after six years of the default. The NCLAT held that limitation began from when the Insolvency Code came into force (2016), making the application timely. The Supreme Court reversed this, holding that Article 137 of the Limitation Act (the residuary article for applications) applies, not Article 62 (applicable only to suits). The three-year limitation period begins when the debt became due (2011), making the application time-barred. The Court emphasized that there is no equity in limitation and rejected any commercial reinterpretation of the Limitation Act.

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