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

The appellants filed an appeal under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, challenging the award dated 23 August 2024 in LAC No. 2626/2020.

The appeal was filed on 20 January 2025 with a delay of 412 days; the appellants sought condonation by an application filed on 3 September 2026, citing administrative reasons and movement of files.

Section 74(1) of the 2013 Act provides for an appeal in land-acquisition matters; the application to condone delay was assessed under the principles governing Section 5 of the Limitation Act.

As stated in Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, limitation serves public policy and delay is not to be condoned merely because the litigant is the State; the applicant must establish a reasonable, satisfactory and bona fide explanation, and administrative lethargy alone is insufficient.

The Court also relied on State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, which reiterates that condonation is discretionary and an excuse is not an explanation.

The affidavit offered general references to file movement and administrative approvals but identified no relevant dates and did not account for the entire period of delay.

Applying the requirement of a specific, satisfactory and bona fide explanation, the Court held that these assertions amounted to an excuse rather than sufficient cause. It also found no demonstrated bona fide effort to file within limitation.

It dismissed I.A. No. 01/2026 and, consequently, dismissed the appeal; any pending applications were also disposed of.