Administrative Laxity and Frivolous Grounds Are Insufficient to Condone Inordinate Delay in Filing Review Petitions.

The petitioners filed a review petition challenging the judgment dated 05.10.2012 passed in Second Appeal No. 265/1996, which had allowed the respondent’s appeal and affirmed the trial court's decree

Along with the petition, the petitioners filed I.A. No. 6379/2026 seeking condonation of a 4,880-day delay (over 13 years)

They contended the delay was bona fide, arising because their counsel failed to appear, leading to an ex-parte decision they were unaware of until obtaining a certified copy on 03.04.2025

The Respondent/State opposed the application citing the inordinate length of the delay

Whether the petitioners established "sufficient cause" under Section 5 of the Limitation Act to condone a delay of 4880 days in filing the review petition.

The Court applied Section 5 of the Limitation Act regarding condonation of delay and the equitable principle that "delay defeats equity"

Pundlik Jalam Patil v. Executive Engineer, Jalgaon Medium Project (2008) 17 SCC 448, establishing that courts help the vigilant and not those who slumber over their rights

The Court further applied the ratio from Majji Sannemma @ Sanyasirao v. Reddy Sridevi AIR 2022 SC 332 and Shivamma (dead) by LRs v. Karnataka Housing Board, Civil Appeal No. 11794/2025, which held that administrative lethargy, laxity, or superficial grounds do not constitute "sufficient cause," and that litigation must attain finality to protect private litigants from perpetual legal battles

The Court found the petitioners' justifications—primarily blaming counsel's non-appearance and claiming a lack of knowledge—to be "merely administrative" and insufficient to explain a 13-year lapse

Applying the Pundlik Jalam Patil precedent, the Court reasoned that the petitioners failed to demonstrate due diligence or provide a satisfactory explanation for their inaction

Referring to the Shivamma judgment, the Court emphasized that courts should not act as "surrogates for laxity" and must remain cautious when reopening matters with inordinate delays, as doing so frustrates the fruits of decrees obtained by the opposing party and violates the principle of finality in litigation

the Court rejected I.A. No. 6379/2026 and dismissed the review petition as time-barred