Distinction between extension of time under Section 5 and exclusion of time under Section 14

A fundamental conceptual distinction exists between the extension of time under Section 5 of the Limitation Act, 1963 and the exclusion of time under Section 14. Section 5 involves the exercise of judicial discretion to excuse an existing delay and stretch the limitation period upon showing "sufficient cause," whereas Section 14 mandates the arithmetic exclusion of time spent diligently prosecuting a bona fide proceeding in a court lacking jurisdiction. While underlying principles of Section 14 may be extended by analogy to tribunals to prevent injustice, the discretionary power under Section 5 cannot be so applied to quasi-judicial bodies without explicit legislative authorization. (The Property Company (P) Ltd. v. Rohinten Daddy Mazda | 2026 INSC 33)