I'll research this systematically — first finding the statutory text and then the key judicial interpretations on when limitation begins to run under Article 113, including the 'knowledge' vs. 'full knowledge' distinction.

Now let me verify the key paragraph citations from the most critical cases before composing my answer.

Limitation under Article 113: Cause of Action, Knowledge, and the "Full Knowledge" Standard

I. The Statutory Text

Article 113, Schedule to the Limitation Act, 1963 provides:

This is the residuary article — it applies only when no other article in the Schedule governs the suit. The critical trigger phrase is "when the right to sue accrues", which does not specify a particular event or type of knowledge.

II. From Cause of Action or From Knowledge? The Key Distinction

The answer depends on a deliberate legislative choice embedded in the difference between Article 113 and Article 58.

A. Article 113 ("accrues") vs. Article 58 ("first accrues")

The Supreme Court's leading authority on this point is Shakti Bhog Food Industries Ltd. v. Central Bank of India, AIR 2020 SC 2721. The Court drew a sharp distinction:

"The expression used in Article 113 is distinct from the expressions used in other Articles… such as Article 58 (when the right to sue "first" accrues), Article 59 (when the facts… "first" become known to him) and Article 104 (when the plaintiff is "first" refused the enjoyment of the right)." — ¶10 (Indian Kanoon)

The operative holding at ¶21:

"Whereas in terms of Article 58 the period of three years is to be counted from the date when 'the right to sue first accrues', in terms of Article 113 thereof, the period of limitation would be counted from the date 'when the right to sue accrues'. The distinction between Article 58 and Article 113 is, thus, apparent inasmuch as the right to sue may accrue to a suitor in a given case at different points of time." — ¶21 (Indian Kanoon)

This distinction was traced to its legislative origins in Khatri Hotels Pvt. Ltd. v. Union of India, (2011) 9 SCC 126:

"While enacting Article 58 of the 1963 Act, the legislature has designedly made a departure from the language of Article 120 of the 1908 Act. The word 'first' has been used between the words 'sue' and 'accrued'. This would mean that if a suit is based on multiple causes of action, the period of limitation will begin to run from the date when the right to sue first accrues." — (Indian Kanoon)

Practical consequence:

B. Knowledge as the Trigger for Accrual

Under Article 113, the "right to sue" does not necessarily accrue upon the bare occurrence of the wrongful act. Where the claimant cannot know of the facts giving rise to the cause of action, the right to sue accrues only upon knowledge or discovery of those facts.

The foundational authority is Salonah Tea Company Ltd. v. Superintendent of Taxes, (1988) 1 SCC 401, where the Supreme Court held:

Sikri, J. was of the opinion that the petitioners were under a mistake of law, the mistake was discovered, like all assessees, when the Court struck down section 12A(4)… and they came to this Court within six months of that date and hence there was no delay. Hegde, J.… observed that "mere impression of a party that a provision of law might be ultra vires cannot be equated to knowledge that the provision was invalid." — (Indian Kanoon)

Under Article 113, limitation for recovery of tax paid under an ultra vires provision ran from the date the claimant gained knowledge that the provision was invalid — not from the date of payment. Mere suspicion that a law "might be" invalid ≠ knowledge of invalidity.

Similarly, in Ghewarchand v. Mahendra Singh, (2018) 10 SCC 588, the Supreme Court held that limitation was rightly counted from when the plaintiffs first had knowledge of the adverse assertion of right over their property — not from when the adverse claim might theoretically have arisen. (Indian Kanoon)

III. The Distinction Between "Knowledge" and "Full Knowledge"

The case law draws a meaningful distinction across several dimensions of knowledge. While no single Supreme Court judgment has laid down a comprehensive taxonomy, the following principles emerge:

A. Full Knowledge vs. Mere Suspicion

The clearest articulation of this distinction comes from In Re: Marappa Goundar, AIR 1959 Mad 26, which, while decided under the old Limitation Act, states a principle that carries forward:

"The knowledge required by the section is not mere suspicion, but full knowledge of such a character as will enable the person defrauded to seek his remedy in court." — (Indian Kanoon)

The standard is thus:

This was echoed in Salonah Tea where the Supreme Court held that a mere impression that a provision "might be" ultra vires could not be equated to knowledge of invalidity.

B. Actual Knowledge vs. Deemed/Constructive Knowledge

The Supreme Court in Mukund Bhavan Trust v. Shrimant Chhatrapati Udayan Raje, (2024) SC, established that knowledge need not be subjectively acquired — it can be imputed:

"Whenever a document is registered, the date of registration becomes the date of deemed knowledge. In other cases where a fact could be discovered by due diligence then deemed knowledge would be attributed to the plaintiff because a party cannot be allowed to extend the period of limitation by merely claiming that he had no knowledge." — (Indian Kanoon)

The Court applied a "prudent man" standard: where facts were discoverable through reasonable diligence, the claimant is fixed with knowledge even if they claim subjective ignorance. (Indian Kanoon)

C. "Full Knowledge" Through Imputation

In Md. Noorul Hoda v. Bibi Raifunnisa, AIRONLINE 1995 SC 608, the Supreme Court used the concept of "full knowledge" in the context of imputed knowledge:

"Rafique had full knowledge that despite the purported sale, Bibi Raifunnisa got the preliminary decree passed in 1973 and in 1974 under the final decree the right, title and interest in the suit property passed on to her. Under Section 55 when second sale deed… was got executed by the petitioner from Rafique, it is imputable that Rafique had conveyed all the knowledge of the defects in title." — (Indian Kanoon) (as quoted in Mukund Bhavan Trust)

Here, "full knowledge" of the predecessor was imputed to the successor by operation of Section 55 of the Transfer of Property Act — the petitioner was fixed with constructive notice of facts his benamidar knew.

D. Deemed Knowledge ≠ Actual Knowledge (for Deliberate Suppression)

An important nuance was drawn by the Bombay High Court in Sulochana Neelkanth Kalyani v. Takle Investments Company, (2016) Bombay HC:

"Deemed knowledge may at best support a case of binding nature of the document but cannot sustain a plea of actual knowledge and deliberate suppression based on such actual knowledge." — ¶22–23 (Indian Kanoon)

This means that while deemed/constructive knowledge suffices for starting limitation, it does not equate to actual subjective knowledge for purposes like proving a party deliberately suppressed facts.

E. Knowledge of Draft vs. Final Act

In Smt. Rubi Rai Tirkey v. State of Jharkhand, (2025) Jharkhand HC, the Court held that knowledge of a draft/preliminary proceeding does not constitute knowledge of the finally published record of rights:

"The disposal of the objection raised by the State regarding the draft publication of the record of rights cannot be treated as the date of knowledge of the finally published record of rights." — (Indian Kanoon)

This reinforces the "full knowledge" standard: knowledge of a preliminary or incomplete proceeding ≠ knowledge of the final operative fact that gives rise to the cause of action.

IV. Section 17 — Fraud/Mistake: The Reasonable Diligence Standard

Where the cause of action is founded on fraud or mistake, Section 17 of the Limitation Act postpones the commencement of limitation. The Supreme Court in Saranpal Kaur Anand v. Praduman Singh Chandhok, (2022) SC, laid down the comprehensive test:

"The period of limitation for filing of the suit shall not begin to run until the plaintiff or applicant has discovered the fraud/mistake or could with reasonable diligence have discovered it." — ¶11 (Indian Kanoon)

Crucially, Section 17 does not protect wilful ignorance:

"Section 17(1) does not assist a person who merely shuts his eyes in spite of circumstances requiring him to ascertain facts on which he would have discovered the fraud." — ¶23 (Indian Kanoon)

The Court also prescribed strict pleading requirements: the plaintiff must state (i) the date on which he discovered the fraud or mistake, and (ii) that he could not have discovered it with reasonable diligence on any earlier date. (¶13, Indian Kanoon)

V. Synthesis: The Knowledge Hierarchy

Drawing together the authorities, the following hierarchy emerges:

Key Takeaways

1. Under Article 113, limitation runs from when the "right to sue accrues" — without the word "first." This permits successive accrual, unlike Article 58 where the earliest cause of action controls.

2. Knowledge matters for accrual: The right to sue does not necessarily accrue upon the occurrence of the wrongful act. Where the claimant could not have known the relevant facts, limitation runs from the date of discovery of those facts — but this is subject to the reasonable diligence standard.

3. "Full knowledge" is the threshold, not mere suspicion: The knowledge required is "of such a character as will enable the plaintiff to institute proceedings." But this does not mean subjective, personal, first-hand knowledge — constructive, deemed, and imputed knowledge satisfy the test.

4. A party cannot extend limitation by claiming ignorance of facts that were discoverable through due diligence. Courts will impute knowledge from the date a reasonable, prudent person would have discovered the relevant facts.

5. Section 17 provides an independent ground for postponement of limitation in cases of fraud or mistake, but it imposes a dual test: actual discovery or when the party "could with reasonable diligence have discovered" the fraud/mistake — whichever is earlier.