Chhattisgarh High Court

Administrative formalities do not constitute sufficient cause for condoning inordinate delays in State-filed appeals.

STATE OF CHHATTISGARH vs CHANDRA SHEKHAR SAHU

Chhattisgarh High CourtJUDGMENT: March 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellants (State of Chhattisgarh and its officials) preferred a writ appeal against an order dated July 2, 2025, passed by a Single Judge in WP(S) No. 1182/2018, which had allowed the writ petition filed by the Respondent

Source reference: para 2

The appeal was filed with a delay of 193 days beyond the prescribed limitation period

Source reference: para 1

The Appellants filed I.A. No. 2 of 2026 seeking condonation of this delay, attributing the lapse to the administrative complexities of the State as a "multi-functioning body," including the time required for obtaining sanctions and completing departmental formalities

Source reference: paras 3-4
02

Issues

Whether the Appellants demonstrated "sufficient cause" to warrant the condonation of a 193-day delay in filing the writ appeal

Source reference: paras 6, 9
03

Law Applied

Section 5 of the Limitation Act regarding the condonation of delay

Source reference: para 6

State of Haryana v. Chandra Mani (1996) 3 SCC 132 regarding government procedural delays

Source reference: para 4

Union of India v. Tarsem Singh (2008) 8 SCC 652, which establishes that belated service-related claims should generally be rejected unless they involve a "continuing wrong" that does not affect the settled rights of third parties

Source reference: para 7

Doctrine from C. Jacob v. Director of Geology and Mining (2008) 10 SCC 115, which holds that stale or dead claims cannot be revived by departmental representations and that misplaced sympathy in condoning inordinate delays results in a drain on the public exchequer

Source reference: para 8
04

Reasoning

The Court analyzed whether the Appellants' justification of administrative "multi-functioning" constituted a valid ground for condonation.

Source reference: para 5

Upon a specific query, the Court found that the Appellants failed to offer any "plausible explanation" or "cogent reason" for the 193-day delay

Source reference: para 5

The Court observed that while the State must follow internal rules for sanctions, the Appellants failed to demonstrate "sufficient cause" as required by law

Source reference: para 9

Integrating the principles from Tarsem Singh and C. Jacob, the Court reasoned that the delay was not satisfactorily explained and that the discretionary power to condone delay should not be exercised in the absence of a bona fide justification

Source reference: paras 9-10
05

Holding

The Court held that the Appellants failed to justify the inordinate delay of 193 days with any satisfactory or cogent reasoning

The Court rejected I.A. No. 2 of 2026 for condonation of delay; As a result of the rejection of the delay application, the writ appeal was dismissed as barred by limitation

Source reference: para 10
Chhattisgarh High Court

Original Court PDF

STATE OF CHHATTISGARHvsCHANDRA SHEKHAR SAHU

Chhattisgarh High Court · March 23, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment