A detailed, verifiable chronology can constitute sufficient cause to condone substantial governmental delay.

The Appellants sought condonation of substantial delays in filing appeals against the common judgment dated 18 August 2022, which directed recomputation of the Respondents’ Special Rehabilitation Package (SRP), with arrears and interest.

The filing delays ranged from 1,182 to 1,436 days; re-filing delays of 23 and 32 days arose in two appeals.

The Appellants attributed the delay to internal consideration of the judgment, a decision to challenge the SRP computation, prosecution of a review petition until its dismissal on 25 February 2025, and subsequent approvals and preparation of the appeals, filed on 12 December 2025.

The Respondents opposed condonation, relying on the prior dismissal of a delayed review petition, the Appellants’ failure to comply with the judgment, and their conduct in the related contempt proceedings.

Whether the Appellants had shown sufficient cause to condone the delays in filing and re-filing the appeals under Section 5 of the Limitation Act.

Whether the prior dismissal of the delayed review petition and the Appellants’ participation in contempt proceedings precluded condonation or demonstrated abuse of process or lack of bona fides.

Order XLI Rule 3A and Section 151 of the Code of Civil Procedure, 1908, read with Section 5 of the Limitation Act, governed the applications for condonation.

The length of delay is not determinative; the central question is whether the explanation is genuine, reasonable, and sufficient. A particularised account of the material periods may justify condonation, while mere invocation of governmental red tape does not; the State receives no automatic preferential treatment.

The Court applied Collector, Land Acquisition, Anantnag v. Mst. Katiji, (1987) 2 SCC 107, and Sheo Raj Singh v. Union of India, (2023) 10 SCC 531, on a justice-oriented approach and the acceptability of the explanation as the controlling consideration.

It considered Post Master General v. Living Media Ltd., (2012) 3 SCC 563, and State of Madhya Pradesh v. Bheru Lal, (2020) 10 SCC 654, as requiring a cogent, particularised explanation rather than a general assertion of administrative delay.

A review and an appeal are distinct remedies, and dismissal of a delayed review does not itself bar a subsequent appeal where its delay is independently explained.

The Court found that the Appellants had provided a continuous, date-specific account of the administrative and legal steps leading to the appeals, including the review proceedings and subsequent approvals; the record did not show that the files had remained dormant or unaccounted for.

It distinguished the present explanation from the generalised explanations rejected in Post Master General and Bheru Lal.

The prior review proceedings did not bar the appeals because the remedies were distinct and the review had been dismissed without determination of the merits; participation in contempt proceedings likewise did not waive the right to challenge the underlying judgment.

The Court also considered the public-exchequer issue raised by the disputed SRP methodology and observed that the Respondents’ entitlement to interest under the common judgment continued during the appeals, while costs could address the prejudice caused by delay.

It concluded that the explanation was sufficient and did not establish deliberate inaction or lack of bona fides.

The connected appeals were listed for hearing on 8 December 2026.