Limitation Act 1963 applies to Public Liability Insurance Act proceedings as the Collector functions as a Civil Court.

The petitioners’ father died of electrocution on 28.04.2015 at age 30.

At the time of their father's death, the petitioners were aged 9 and 7 years.

Upon the first petitioner attaining majority, they filed a claim for compensation under Section 6(3) of the Public Liability Insurance Act (PLIA), 1991.

The Collector rejected the application on 05.06.2025, holding it time-barred as Section 6(3) prescribes a five-year limitation period from the date of the accident, and the petitioners’ application under Section 14 of the Limitation Act was filed belatedly.

The petitioners challenged this via a writ petition under Article 226.

Whether the Collector, while adjudicating claims under the Public Liability Insurance Act, 1991, functions as a 'Court' for the purpose of the Limitation Act, 1963.

Whether the provisions of the Limitation Act, 1963, specifically regarding legal disability (minority), apply to applications filed under Section 6 of the PLIA.

Section 6(3) of the Public Liability Insurance Act, 1991, which sets a five-year limitation for relief applications.

Section 29(2) of the Limitation Act, 1963, which stipulates that where a special law prescribes a different limitation period, Sections 4 to 24 apply unless expressly excluded.

Sections 6 and 8 of the Limitation Act regarding legal disability, allowing minors to file applications within three years after the disability ceases.

Statutory duty of the Collector under Section 5 of the PLIA to verify accidents and invite claims.

Consolidated Engg. Enterprises v. Irrigation Deptt. regarding the non-exclusion of the Limitation Act by special statutes.

The Court reasoned that the Collector functions as a "Court" because Section 7(5) of the PLIA confers the powers of a Civil Court for evidence and discovery, and Rule 5(ii)(h) specifically grants the Collector inherent powers under Section 151 of the CPC.

Since the PLIA does not expressly exclude the Limitation Act, the Court held that Section 29(2) makes Sections 4 to 24 of the Limitation Act applicable.

The Court noted that as a beneficial piece of legislation, the PLIA's five-year limit cannot be used to penalize minors for a legal disability.

Additionally, the Court found the Collector at fault for failing to perform the mandatory statutory duty under Section 5 of the PLIA, which requires the Collector to proactively invite applications through publication.

Consequently, since the petitioners filed shortly after attaining majority, they were entitled to the protection afforded by Sections 6 and 8 of the Limitation Act.

It held that the Limitation Act, 1963 applies to proceedings under the PLIA and that the petitioners were entitled to seek relief within three years of attaining majority.

The matter was remanded to the Collector, Lakhimpur Kheri, with a direction to decide the claim on merits within three months, as mandated by Section 7(7) of the PLIA.