It’s time for some limitations pedantry!
In Corona Steel Industry Private Ltd. V. Integrity Worldwide Inc., the court held that “an action for recognition and enforcement of a foreign judgment is treated as an action upon a simple contract for purposes of determining the limitation period.”
This was so until 2004 when the current Limitations Act came into force. The Limitations Act does not distinguish between categories of contracts, or causes of action. The Limitations Act asks when the plaintiff discovered a “claim” (as defined by s. 1). The Court of Appeal made the point explicit in addressed the issue squarely in Independence Plaza.
I think perhaps counsel had relied on a previous version of the Law of Limitations, or some obsolete jurisprudence.
