As there is no specific provision enabling the Limitation period for the proceedings under the Code, at the time of introduction of the Insolvency and Bankruptcy Code, 2016 , there was a confusion regarding the applicability of the Limitation Act, 1963 to the applications that are being filed under section 7 and 9 of the Code. It had become a norm that, the date of coming into force of IBC Code shall be the trigger point of limitation for application filed under the Code. The said confusion had thrown open the dormant cases and the litigants started approaching the Adjudicating Authority (AA) in a manner resembling to the honey bees whose Beehive got stoned. Subsequently, the said doubt had got alleviated through various judgments of the Supreme Court of India and the National Company Law Board Tribunal and it got crystallized that the Article 137 of the Limitation Act, 1963 is Article 137 of Limitation Act, 1963 for moving application under section 7 or 9 of the I&B Code. As per Article 137, any other application for which no period of limitation is provided elsewhere, then the Limitation Period is 3(Three) years.
In Vashdeo R. Bhojwani v. Abhyudaya Co-operative Bank Ltd.  109 taxmann.com 198/156 SCL 539, the Hon'ble Supreme Court referring to B.K. Educational Services (P.) Ltd. (supra) observed: —
"42. It is thus clear that since the Limitation Act is applicable to applications filed under sections 7 and 9 of the Code from the inception of the Code, Article 137 of the Limitation Act gets attracted. "The right to sue", therefore, accrues when a default occurs. If the default has occurred over three years prior to the date of filing of the application, the application would be barred under Article 137 of the Limitation Act, save and except in those cases where, in the facts of the case, section 5 of the Limitation Act may be applied to condone the delay in filing such application.
Thus through various decisions, it became very clear that the date of coming into force of IBC Code does not and cannot form a trigger point of limitation for application filed under the Code. Equally, since "applications" are petitions, which are filed under the Code, it is Article 137 of the Limitation Act, 1963 which will apply to such applications.
Bijoy P Pulipra