The Year That Wasn't

Introduction

In March 2020, a full bench of the Hon'ble Supreme Court of India ("SC") vide In Re: Cognizance for Extension of Limitation¹ ("Extension of Limitation") took suo moto cognizance of the difficulties faced by litigants on account of the nation-wide lockdown due to the COVID-19 pandemic. Given the practical problems in filing suits, applications, petitions, appeals and any other proceedings within the limitation period, the SC on March 23, 2020, passed an order extending the limitation period prescribed under the general and special laws with retrospective effect from 15.03.2020, until further orders ("Order dated 23.03.2020"). The SC exercised this power under Article 142 read with Article 141 of the Constitution of India and declared that this order is binding within the meaning of Article 141 on all Courts/Tribunals and authorities across the nation. Although the SC extended the Order dated 23.03.2020 from time to time, there were certain