Administrative delays and subsequent judicial developments do not constitute sufficient cause for condoning inordinate delay in filing review applications.

The Municipal Corporation of Delhi (MCD) filed a Miscellaneous Application (MA) seeking condonation of a 661-day delay in filing a Review Application (RA) against an order dated 27.02.2024

The MCD contended the delay was due to bureaucratic processing across multiple departments (Accounts, Finance, Legal) and high administrative workload

Additionally, the MCD argued that a subsequent legal clarification regarding the rate of interest on retiral dues was only settled by a Full Bench of the Tribunal in Rajbir Singh vs MCD on 30.10.2025, which necessitated an informed review of the original order

The original applicant, a retired SFW, had been awarded interest on delayed retiral/GPF dues in the impugned order

1. Whether the Tribunal has the jurisdiction to condone a delay in filing a Review Application beyond the 30-day period prescribed under Rule 17 of the CAT (Procedure) Rules, 1987 by invoking Section 5 of the Limitation Act

2. Whether administrative constraints and subsequent judicial pronouncements constitute "sufficient cause" for condoning a delay of 661 days

Rule 17(1) of the Central Administrative Tribunal (Procedure) Rules, 1987 stipulates that a review application must be filed within 30 days of receipt of the order

While the Calcutta High Court in Union of India v. CAT (2002) suggested Section 5 of the Limitation Act could apply via Section 29(2), subsequent decisions like the Gauhati High Court's Union of India v. Chanchal Nag (2023) held that the Tribunal cannot condone such delays in the absence of an express statutory provision

The core doctrine of "sufficient cause" under Section 5 of the Limitation Act requires a liberal but bona fide explanation, excluding routine administrative delays or subsequent changes in law as valid justifications

The Tribunal observed that Rule 17 is mandatory and lacks an express provision for extension

It declined to resolve the conflict between the Calcutta and Gauhati High Court views, noting that even if the power to condone delay existed, the MCD failed to demonstrate "sufficient cause"

The Tribunal rejected the "bureaucratic movement of files" as a vague and unspecific justification for an inordinate 661-day delay

Crucially, the Tribunal held that a subsequent judicial development (the Full Bench judgment in Rajbir Singh) cannot retroactively justify a delay that had already accrued before that judgment was delivered

The Tribunal noted the MCD was not precluded from filing the RA timely and awaiting the Full Bench outcome

The Tribunal held that routine administrative procedures and later judicial clarifications do not constitute "sufficient cause" for a 661-day delay

Consequently, MA No. 2126/2026 for condonation of delay was dismissed, and the accompanying Review Application was dismissed as barred by limitation and not maintainable