Administrative delay and file movement do not constitute sufficient cause to condone delay.

In brief

The question

1. Whether the appellants had shown sufficient, reasonable, and bona fide cause to condone the 698-day delay in filing the appeal

The court held

The Court answered the first issue in the negative: the appellants had not established sufficient cause for condonation of delay.

It also directed

It dismissed I.A. No. 01/2026 and, consequently, dismissed the appeal.

Any pending interlocutory applications were disposed of.

01Facts

The appellants challenged the judgment and award dated 4 July 2023 in LAC No. 349/2019 under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.

¶ 1–3

The appeal was filed on 10 September 2025, with a delay of 698 days. The appellants sought condonation of delay, relying principally on administrative reasons and movement of files; their supporting affidavit did not provide relevant dates or explain the entire period of delay.

¶ 1–3, 9–10

02Issues

i.1. Whether the appellants had shown sufficient, reasonable, and bona fide cause to condone the 698-day delay in filing the appeal

¶ 2–3, 9–10

ii.2. Whether the appeal could proceed where the application for condonation of delay was liable to be rejected

¶ 10

03Law Applied

Section 74(1) of the 2013 Act provides for an appeal to the High Court from an award of the Land Acquisition, Rehabilitation and Resettlement Authority.

p. 3

Applying the principles governing condonation of delay under Section 5 of the Limitation Act, 1963, the Court held that the applicant must establish a sufficient and satisfactory explanation covering the period of delay; administrative lethargy, file movement, and interdepartmental correspondence do not, without more, constitute sufficient cause. The State receives no automatic or special indulgence and must act with diligence.

¶ 5–8

The Court relied principally on Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, and State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, as well as the limitation principles quoted from Basawaraj.

¶ 5–8

Provisions in the judgment · 4 · Linked ones open on LawLens

Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 Section 74

Limitation Act, 1963 Section 3 Section 5

Code of Civil Procedure, 1908 Section 100

04Reasoning

The affidavit offered only general references to administrative processes and approvals, without relevant dates or a reasoned account of the full 698-day delay.

¶ 3–4, 9–10

Applying the cited authorities, the Court found that the explanation was an excuse rather than a bona fide account of sufficient cause. It also observed that no satisfactory explanation showed what prevented the appellants from filing within limitation; the merits of the underlying appeal could not compensate for that failure.

¶ 3–4, 9–10