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Supreme Court of India 2019-09-18 allowed

Gaurav Hargovindbhai Dave vs Asset Reconstruction Company (India) Ltd. & Anr

Bench: 3 — R.F. Nariman

In Brief

The Supreme Court considered whether a debt recovery application under Section 7 of the Insolvency and Bankruptcy Code was time-barred. The core issue was which article of the Limitation Act applied: Article 62 (for suits to enforce payment of secured money) or Article 137 (residuary article). The Court held that since Section 7 proceedings are 'applications' not 'suits', Article 137 applies, and the limitation period runs from the date of default (2011), not from when the Code came into force (2016). Accordingly, an application filed in 2017 was time-barred. The Court rejected commercial interpretation as a basis to circumvent limitation law.

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Insolvency and Bankruptcy Limitation Debt Recovery Asset Reconstruction Commercial Law

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