Absence of Plausible Explanation for Administrative Procedures Precludes Condonation of Delay for State Authorities.

The State of Chhattisgarh (Appellants) filed a writ appeal challenging the order dated 09.07.2025 passed by a Single Judge in WPS No. 7887 of 2018.

The appeal was filed with a delay of 164 days beyond the prescribed limitation period.

The Appellants filed I.A. No. 01 of 2026 for condonation of delay, citing administrative reasons including the time taken to obtain legal opinions from the Advocate General, obtaining permission from the Law Department, and appointing an Officer-in-Charge (OIC) to collect records.

The Appellants claimed these delays were due to the multi-functional nature of government machinery and were bona fide.

1. Whether the administrative delays and procedural "red-tapism" within government departments constitute "sufficient cause" for condoning an inordinate delay under Section 5 of the Limitation Act?

The Court primarily applied the principle that the law of limitation binds the Government and individuals equally, as established in *Postmaster General v. Living Media India Limited (2012)*.

It relied on *State of Madhya Pradesh v. Ramkumar Choudhary (2024)*, which held that "sufficient cause" cannot be liberally interpreted if negligence or inaction is attributed to the party and that events occurring after the expiry of the limitation period do not constitute such cause.

The Court further emphasized the doctrine from *Shivamma v. Karnataka Housing Board (2025)* that courts should not become surrogates for State laxity and and lethargy.

The Court scrutinized the Appellants' timeline, noting that while the impugned order was passed in July 2025, the file moved through various departments—Advocate General, Law Department, and OIC—until February 2026.

The Court rejected the argument that "bureaucratic methodology" or "procedural red-tape" justifies delay, especially in the era of modern technology.

Applying *Ramkumar Choudhary*, the Court observed that the State failed to show what prevented them from filing the appeal *within* the 90-day limitation window; instead, they provided a sequence of events that occurred mostly after the limitation had already expired.

The Court found the explanation lacked specificity and failed to demonstrate the "due diligence" required of government departments.

Consequently, the Court declined to exercise its discretionary power to condone the delay, stating that condonation is an exception and not a reward for state apathy.

The writ appeal was dismissed on the grounds of delay and laches.