Absence of plausible explanation for delay in government administrative procedures precludes condonation under Limitation Act.

The Appellants (State of Chhattisgarh) filed a writ appeal challenging the order dated 10.09.2025 passed by a Single Judge in WPS No. 9594 of 2025.

In the original writ, the Single Judge directed the State to grant the Respondent one opportunity for document verification on 24.09.2025 despite her peculiar conditions.

The State preferred the present appeal after a delay of 115 days, filing I.A. No. 01/2026 for condonation of delay.

The State attributed the delay to the administrative complexities of being a "multi-functioning body," necessitating multiple levels of sanction and departmental formalities.

1. Whether the administrative procedures and departmental formalities of the State constitute "sufficient cause" to condone a delay of 115 days under Section 5 of the Limitation Act.

The court primarily assessed the standards for condonation of delay under Section 5 of the Limitation Act, 1908 (consistent with the modern Act).

State of Haryana v. Chandra Mani (1996) 3 SCC 132 regarding the State’s procedural delays.

Union of India v. Tarsem Singh (2008) 8 SCC 652, which establishes that belated service-related claims/appeals are generally rejected on grounds of laches unless there is a "continuing wrong".

C. Jacob v. Director of Geology and Mining (2008) 10 SCC 115, which holds that stale claims or those barred by limitation should not be revived without merit.

The Division Bench scrutinized the State's justification that administrative "red tape" and the requirement for multiple approvals caused the 115-day delay.

The Court noted that despite the State's reliance on Chandra Mani, the Appellants failed to offer a "plausible explanation" or "cogent reason" when specifically queried about the inordinate length of the delay.

Applying the principles in Tarsem Singh and C. Jacob, the Court reasoned that the State must demonstrate "sufficient cause" to justify the exercise of judicial discretion.

The Court found that the explanation provided was generic and failed to prove that the State was prevented by a bona fide cause from filing within the limitation period.

Consequently, the Court rejected I.A. No. 01/2026 and dismissed the writ appeal as time-barred.