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

The appellants challenged the judgment and award dated 13 September 2023 in LAC No. 233/2022 under Section 74(1) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.

The appeal was filed on 26 November 2024 with a delay of 363 days. The appellants sought condonation of delay by I.A. No. 01/2026, attributing it principally to administrative processes and file movement.

The High Court found the supporting affidavit bald and lacking relevant dates.

The appeal was brought under Section 74(1) of the 2013 Act, and the application for condonation was considered under the principles governing Section 5 of the Limitation Act, read with the public-policy requirement of limitation reflected in Section 3.

Relying on 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, the Court held that State authorities receive no automatic or special indulgence; they must provide a reasonable, satisfactory, bona fide explanation covering the period of delay.

Administrative lethargy, file movement, or bureaucratic inefficiency, without a substantiated explanation, does not constitute sufficient cause.

The affidavit relied largely on administrative approvals and movement of files, but did not provide relevant dates or explain the delay throughout the limitation period.

Applying the Supreme Court’s requirement of a bona fide and complete explanation, the Court treated these assertions as an excuse rather than a sufficient explanation.

It found no demonstrated bona fide effort to file the appeal within time and no basis to exercise discretion in the appellants’ favour.

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