In Brief
An employee of a cooperative bank sought to appeal a disciplinary order imposing salary freezement within the prescribed 30-day period under the Madhya Pradesh Cooperative Societies Act, 1960. His application was filed two days late (the deadline fell on a Saturday). The Tribunal rejected it solely on the ground of delay, citing lack of condonation power. The Supreme Court held that Section 29(2) of the Limitation Act, 1963 automatically applies Sections 4–26 (including Section 5 on condonation) to proceedings under special laws unless expressly excluded. The two-day delay falling on weekend days constituted sufficient cause. The Court overruled an earlier precedent and remitted the matter to the Tribunal for decision on merits.
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