Articles 134 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A decree is worth little if it cannot be enforced, and the Schedule to the Limitation Act, 1963 sets the time for that too. Articles 134 to 137 close the Third Division (applications): one year for a purchaser asking for delivery of possession after an execution sale, three years to enforce a decree for a mandatory injunction, twelve years to execute any other decree or order, and three years for any other application.
The text below follows the consolidated text of the Act consulted (latest amendment shown: Act 46 of 1999). Later amendments should be checked.
A purchaser at an execution sale has one year from when the sale becomes absolute to ask for delivery of possession (Article 134). Enforcing a decree for a mandatory injunction has three years from the date of the decree, or the date fixed for performance (Article 135). Executing any other decree or order of a civil court has twelve years from when it becomes enforceable, or from the default where payment or delivery is directed on a date or at recurring periods (Article 136). Any other application with no period elsewhere in the Division has three years (Article 137).
Where these Articles sit
Articles 134 to 136 are in the Third Division (applications), Part I (applications in specified cases), and Article 137 stands alone in Part II. A decree-holder holding a money decree can plan a recovery suit route only for the underlying claim; once the decree exists, execution is the next step, and these Articles fix the time. Our guide to how the Schedule is laid out explains the three columns. For the procedure, see our post on execution of a decree.
Copied as printed:
| Article | Description of suit | Period of limitation | Time from which period begins to run |
|---|---|---|---|
| 134 | For delivery of possession by a purchaser of immovable property at a sale in execution of a decree. | One year. | When the sale becomes absolute. |
| 135 | For the enforcement of a decree granting a mandatory injunction. | Three years. | The date of the decree or where a date is fixed for performance, such date. |
| 136 | For the execution of any decree (other than a decree granting a mandatory injunction) or order of any civil court. | Twelve years. | the decree or order becomes enforceable or where the decree or any subsequent order directs any payment of money or the delivery of any property to be made at a certain date or at recurring periods, when default in making the payment or delivery in respect of which execution is sought, takes place: Provided that an application for the enforcement or execution of a decree granting a perpetual injunction shall not be subject to any period of limitation. |
| 137 | Any other application for which no period of limitation is provided elsewhere in this Division. | Three years. | When the right to apply accrues. |
Printing points. In Article 136, the first word of the third column is printed in square brackets, "", with a footnote marker on the line above. The footnote says the word was substituted in 1964 for "Where". This article gives no Act number for that change, because the footnote and the one on Article 98 give different Act numbers for the 1964 change. The heading of Part II is printed "OTHER APPLICATION" in the singular, though the Article itself says "Any other application".
Article by Article with dates
Under section 12(1), the day from which the period is reckoned is excluded. The examples use future dates for illustration only.
Article 134: delivery of possession after an execution sale. One year "when the sale becomes absolute". If the sale becomes absolute on 14 February 2027, the one year ends on 14 February 2028. The Act does not say when a sale becomes absolute; that is for the procedural law. For a related short period, see the application to set aside an execution sale in Articles 124 to 129.
Article 135: decree granting a mandatory injunction. Three years from "the date of the decree or where a date is fixed for performance, such date". If a decree dated 20 June 2027 fixes no date, the three years end on 20 June 2030. If it fixes 30 September 2027 for performance, the three years run from that date and end on 30 September 2030. The Specific Relief Act, 1963 deals with the relief itself; see our posts on mandatory injunction and perpetual injunction.
Article 136: execution of any other decree or order. Twelve years, from the date the decree or order becomes enforceable. If a decree for a sum of money becomes enforceable on 10 January 2027, the twelve years end on 10 January 2039. Where the decree or any subsequent order directs payment of money or delivery of property to be made "at a certain date or at recurring periods", the period runs from the default "in respect of which execution is sought". Suppose a decree directs payment of Rs 1,00,000 on 1 December 2030 and the judgment-debtor fails to pay on that date; for execution of that default the twelve years end on 1 December 2042. The Article is for decrees and orders of "any civil court", and it excludes a decree granting a mandatory injunction, which is Article 135.
The proviso on perpetual injunctions. An application for the enforcement or execution of a decree granting a perpetual injunction "shall not be subject to any period of limitation". Read it as printed. It does not say anything about other reliefs, and it does not say that the order itself never lapses on other grounds.
Article 137: any other application. Three years "when the right to apply accrues", for any other application for which no period is provided elsewhere in the Division. If the right to apply accrues on 5 November 2027, the three years end on 5 November 2030. The Act does not say when the right to apply accrues; the facts and the nature of the application decide that. Check Articles 118 to 136 first: many common applications, such as review (124), setting aside an ex parte decree (123) and legal representatives (120), have their own periods. See Articles 118 to 123 and Articles 130 to 133. For suits with no period elsewhere, the residuary Article is 113, covered in our article on Articles 111 to 113.
What can change the count
- Section 15(1): where the institution or execution has been stayed by injunction or order, the time of the stay, the day it was issued and the day it was withdrawn are excluded. See section 15.
- Section 15(3): for a suit or application for execution of a decree by a receiver or interim receiver in insolvency proceedings, or a liquidator or provisional liquidator in winding-up proceedings, the period from the date of institution of the proceeding to the expiry of three months from the appointment is excluded.
- Section 4: if the last day falls when the court is closed, the application may be made on the day it re-opens.
- Sections 18 and 19: section 19 says that "debt" does not include money payable under a decree or order of a court, so read both sections carefully before treating a payment or acknowledgment as giving a fresh period for execution. See section 18 and section 19.
- Section 5: it excludes "any application under any of the provisions of Order XXI of the Code of Civil Procedure, 1908". The Schedule does not say whether an application under Article 136 is one of them; take advice before assuming that delay can be admitted.
Special laws
Section 29(2) provides that where a special or local law prescribes a different period, that period applies. Execution of arbitral awards, insolvency orders and decrees under special statutes follows those laws; this article states none of those periods. See our post on enforcement of an arbitral award.
Need help enforcing a decree?
A decree can run for twelve years, but defaults and stays make the count harder than it looks. We can help you review the decree, fix the dates and plan the next step, including any recovery suit that remains open on related claims.
Key takeaways
- Article 134: one year from when the sale becomes absolute, for a purchaser's application for delivery of possession.
- Article 135: three years from the decree (or the date fixed for performance) for a mandatory injunction decree.
- Article 136: twelve years, from enforceability or from the default where payment or delivery is directed on a date or at recurring periods; a perpetual injunction decree has no period of limitation.
- Article 137: three years from when the right to apply accrues, for any other application with no period elsewhere in the Division.
- The print shows "" in Article 136 with a footnote on a 1964 substitution.
- A special or local law may fix a different period; later amendments should be checked.
Read next
- Articles 130–133: pauper appeal, revision and leave to appeal to the Supreme Court
- Articles 124–129: review, instalments and applications in execution
- Articles 111–113: suits by government and local authority, and the residuary article
- Execution petition: decree enforcement procedure
Disclaimer: Based on a consolidated text of the Limitation Act, 1963 and its Schedule whose latest amendment shown is Act 46 of 1999, as consulted on 2 October 2026. A special or local law may fix a different period; later amendments and the current procedural law should be checked. This article is general information, not legal advice; check the official text before acting.