CAT - ['Delhi']

Absence of Cogent Explanation for Enormous Delay Precludes Condonation in Compassionate Appointment Claims

Sunil Bali vs M/O LABOUR AND EMPLOYMENT

CAT - ['Delhi']JUDGMENT: May 14, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Initially, the Tribunal and the High Court of Madhya Pradesh rejected his claims

Source reference: para. 2

the Hon’ble Supreme Court, in Civil Appeal No. 4445/2010 (decided on 27.02.2020), directed the respondents to reconsider his prayer in accordance with the law

Source reference: para. 2

the respondents passed an-impugned order dated 21.10.2020

Source reference: para. 3

The applicant filed the present Original Application (OA) in 2025, accompanied by MA No. 1950/2024, seeking condonation of a 1,134-day delay

Source reference: para. 1
02

Issues

1. Whether the applicant provided "sufficient cause" to condone the 1,134-day delay in filing the Original Application under the Administrative Tribunals Act

Source reference: para. 4-5
03

Law Applied

The court applied Sections 20 and 21 of the Administrative Tribunals Act, 1985, which prescribe the limitation period for filing applications before the Tribunal

Source reference: para. 3

The court also accounted for the extension of limitation periods granted by the Hon’ble Supreme Court In Re: Cognizance for Extension of Limitation due to the COVID-19 pandemic

Source reference: para. 3

The general principle holds that delay can only be condoned upon showing sufficient cause through a factual explanation for every day of the delay

Source reference: para. 4
04

Reasoning

The Tribunal calculated that following the impugned order of 21.10.2020, the statutory limitation expired on 20.10.2021

Source reference: para. 3

Even granting the COVID-19 pandemic extensions, the limitation would have expired by March 2022

Source reference: para. 3

The present OA was filed more than three years after that deadline

Source reference: para. 3

The Tribunal observed that the Miscellaneous Application (MA) for condonation was "bald" and "bereft of any cogent explanation" accounting for the enormous delay

Source reference: para. 4

It reasoned that mere reliance on legal precedents or the applicant's status as unemployed does not constitute a factual explanation for the passage of time

Source reference: para. 4

Consequently, in the absence of a date-wise or satisfactory explanation, the statutory bar of limitation could not be lifted

Source reference: para. 4-5
05

Holding

The Tribunal answered the issue in the negative, finding no sufficient cause for the delay.

The Court dismissed MA No. 1950/2024 for condonation of delay. Resultantly, the Original Application (OA No. 1690/2025) and all pending applications were disposed of as barred by limitation. No costs were awarded.

Source reference: para. 5
CAT - ['Delhi']

Original Court PDF

Sunil BalivsM/O LABOUR AND EMPLOYMENT

CAT - ['Delhi'] · May 14, 2026

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