Administrative delays do not constitute sufficient cause for condoning delay in Section 37 arbitration appeals.

Land belonging to Respondent No. 1 was acquired under the National Highways Act, 1956, for widening National Highway No. 200, and a compensation award was passed on 16.04.2018.

Dissatisfied, the respondent sought enhancement under Section 3G(5) of the Act.

The Arbitrator, vide award dated 21.02.2023, remanded the matter to the Competent Authority for Land Acquisition (CALA) for a revised award.

The appellant challenged this under Section 34 of the Arbitration and Conciliation Act, 1996, but the District Court dismissed the application on 27.09.2024, observing the Arbitrator acted beyond the scope of Section 3G(5).

The appellant filed the present appeal under Section 37 on 02.04.2025, with a delay of 101 days beyond the prescribed limitation period.

Whether the appellant demonstrated "sufficient cause" under Section 5 of the Limitation Act to condone the 101-day delay in filing the arbitration appeal.

The court applied Section 37 of the Arbitration and Conciliation Act, 1996, read with Section 5 of the Limitation Act.

It relied on the precedent set by the Supreme Court in Government of Maharashtra v. Borse Brothers Engineers and Contractors Pvt. Ltd. (2021) 6 SCC 460, which held that for appeals under Section 37, delay beyond the 60/90-day period should be condoned only as an exception and not as a rule, keeping in view the objective of speedy disposal.

It further applied the principle from Ramlal v. Rewa Coalfields Ltd., stating that the proof of "sufficient cause" is a condition precedent to the exercise of discretionary jurisdiction, and even if shown, condonation is not a matter of right.

The court scrutinized the appellant’s explanation for the 101-day delay, which cited administrative exigencies: the time taken for legal opinions, departmental approvals, the superannuation of the officer-in-charge, and the intervening winter vacation.

The court found these explanations to be vague, general, and representative of gross negligence rather than "sufficient cause".

Applying the Borse Brothers standard, the court observed that for arbitration matters, the appellant must act bona fide and with extreme diligence.

It held that the administrative hurdles described did not satisfy the rigorous standard required to overcome the statutory bar of limitation, describing the explanation as "woefully short".

The court noted that identical issues regarding delay by the same department had already been dismissed in previous rulings like Sumitra Bai v. Executive Engineer, PWD.

I.A. No. 2 of 2025 for condonation of delay was rejected, and consequently, the arbitration appeal was dismissed.