Administrative lethargy and file movement do not constitute sufficient cause to condone delay.

In brief

The question

Whether the appellant established sufficient, reasonable, and bona fide cause to condone the 560-day delay in filing the appeal.

The court held

The Court held that the delay was not satisfactorily, reasonably, or bona fide explained and dismissed I.A. No. 01/2026.

It also directed

Consequently, the appeal was dismissed, and any pending interlocutory applications were disposed of.

01Facts

The Special Land Acquisition Officer appealed under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, against the award dated 13 September 2023 in LAC No. 2064/2021.

p. 1

The appeal was filed on 16 June 2025 with a delay of 560 days.

p. 2 · ¶ 1–3

The appellant sought condonation by I.A. No. 01/2026, relying principally on administrative reasons and movement of files.

p. 2 · ¶ 1–3

The High Court found the affidavit bald and lacking relevant dates or an explanation covering the period of delay.

pp. 12–14 · ¶ 9–10

02Issues

i.Whether the appellant established sufficient, reasonable, and bona fide cause to condone the 560-day delay in filing the appeal.

pp. 2, 12–14 · ¶ 2–3, 9–10

ii.Whether administrative delay and inter-departmental file movement, without a satisfactory explanation for the entire period of delay, warranted condonation.

pp. 12–14 · ¶ 9–10

03Law Applied

Section 74(1) of the 2013 Act provides for an appeal against the relevant award.

p. 1

In considering condonation of delay, the Court applied the principles stated in Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, and State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191: a party seeking condonation must provide a reasonable and satisfactory explanation for the delay; the State receives no automatic preferential treatment; and administrative lethargy or file movement, without a bona fide explanation covering the delay, does not by itself constitute sufficient cause.

pp. 3–12 · ¶ 5–8 · pp. 12–14 · ¶ 9–10

Provisions in the judgment · 4 · Linked ones open on LawLens

Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 Section 74

Limitation Act, 1963 Section 5 Section 3

Code of Civil Procedure, 1908 Section 100

04Reasoning

The affidavit relied largely on administrative approvals and movement of files, but supplied no relevant dates or account of what prevented the appellant from filing within the prescribed period.

pp. 12–14 · ¶ 9–10

Applying the Supreme Court’s guidance that the State must act with diligence and that condonation cannot be routine, the Court treated the explanation as an excuse rather than a bona fide cause.

pp. 12–14 · ¶ 9–10

It also observed that the appeal appeared to have been filed to frustrate execution proceedings.

p. 2 · ¶ 4

The appellant therefore failed to establish sufficient cause for the delay.

pp. 12–14 · ¶ 9–10