Administrative delay and file movement do not constitute sufficient cause to condone the State’s delay.

The appellants challenged the judgment and award dated 21 April 2023 in LAC No. 662/2021, passed by the I Additional District Judge and Land Acquisition, Rehabilitation and Resettlement Authority, Vijayapura.

The appeal under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, was filed on 19 June 2025 with a stated delay of 672 days.

The appellants sought condonation of delay by I.A. No. 01/2026, relying principally on administrative reasons and the movement of files.

The High Court found the supporting affidavit bald and lacking relevant dates.

Section 74(1) of the 2013 Act provides for an appeal from the relevant award or decision.

An application to condone delay requires a reasonable and satisfactory explanation that covers the period of delay; governmental authorities receive no automatic or special exemption from limitation requirements.

In Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, the Supreme Court reiterated that public interest is served by timely and accountable governmental action, and that administrative lethargy or laxity does not, by itself, constitute sufficient cause.

The Court also relied on State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, which distinguished a genuine explanation from a mere excuse and affirmed that condonation is discretionary, not a matter of right.

The judgment further cited the principle in Basawaraj that limitation must be applied as prescribed and cannot be extended on equitable grounds.

The appellants’ affidavit relied largely on file movement and administrative approvals, but supplied no relevant dates or specific account of what prevented timely filing.

It therefore neither explained the entire period of delay nor established bona fide diligence.

Applying the cited Supreme Court authorities, the Court held that administrative delay and inter-departmental correspondence were insufficient, and that the State and its instrumentalities must meet the same limitation requirements as other litigants.

As no satisfactory cause was shown, the Court rejected the condonation application without proceeding to the merits of the appeal.

It dismissed I.A. No. 01/2026 and, consequently, dismissed the appeal; pending applications, if any, were also disposed of.