Administrative delay in public sector undertakings does not constitute sufficient cause for condoning inordinate delay.

The Appellants (South Eastern Coalfields Ltd., a Public Sector Undertaking) filed a writ appeal challenging the order dated 07.07.2025 passed by a learned Single Judge in W.P.(S) No. 6250/2018.

The appeal was filed with a delay of 159 days beyond the 45-day statutory limitation period.

The Appellants filed I.A. No. 01 seeking condonation of delay, citing procedural and administrative hurdles inherent in a Government Company, including the movement of files between the Area Office and Headquarters for legal sanction.

The State respondents opposed the application, arguing the explanation was vague and failed to show due diligence.

1. Whether the administrative and procedural delays inherent in a Public Sector Undertaking constitute "sufficient cause" for condoning an inordinate delay of 159 days under the law of limitation.

The Court applied Section 2(1) of the Chhattisgarh High Court (Appeal to Division Bench) Act, 2006, which prescribes a 45-day limitation period.

It relied on the Supreme Court precedents in Postmaster General v. Living Media India Limited (2012), which established that government departments do not have a separate, liberal period of limitation and must explain delays without relying on "bureaucratic methodology".

The Court also 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 subsequent events after the expiry of limitation cannot justify the initial failure to file within time.

The Court observed that while a liberal approach is sometimes taken to advance substantial justice, the law of limitation binds the Government and private litigants equally.

The Appellants provided a "stereotyped" and "routine" explanation involving internal correspondence and administrative approvals but failed to furnish specific dates or demonstrate time-bound steps taken within the original 45-day period.

The Court reasoned that being a Public Sector Undertaking equipped with a full-fledged legal machinery, the Appellants were expected to act with promptitude rather than "deep slumber".

Since the explanation was vague and lacked bona fides, it did not satisfy the "sufficient cause" requirement.

Consequently, the Court rejected I.A. No. 01 for condonation of delay and dismissed the writ appeal as barred by limitation and laches, without addressing the merits of the case.