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

In brief

The question

1. Whether the appellants established sufficient cause to condone the 454-day delay in filing the appeal

The court held

The Court dismissed I.A. No. 01/2026 for failure to establish sufficient cause for the delay.

It also directed

Consequently, it dismissed the appeal; any pending interlocutory applications were also disposed of.

01Facts

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 15 July 2023 in L.A.C. No. 1610/2019.

pp. 3–4

The appeal was filed on 10 December 2024, with a delay of 454 days.

pp. 3–4

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

pp. 3–4

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

pp. 13–14

02Issues

i.1. Whether the appellants established sufficient cause to condone the 454-day delay in filing the appeal

pp. 3–4, 13–14

ii.2. Whether the appeal could proceed once the application for condonation of delay was rejected

p. 14

03Law Applied

Under the principles governing condonation of delay, the applicant must provide a reasonable, satisfactory, bona fide explanation covering the period of delay; administrative lethargy, file movement, and inter-departmental correspondence do not, without more, constitute sufficient cause.

pp. 4–11

Government authorities receive no special privilege in limitation matters and are required to act diligently and promptly.

pp. 4–11

The Court relied on Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, including its emphasis on limitation as a matter of public policy and on requiring accountability from State authorities, and State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, on the distinction between a genuine explanation and a mere excuse and the discretionary nature of condonation.

pp. 4–13

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 appellants’ affidavit attributed the delay generally to administrative reasons, file movement, and approvals, but did not provide relevant dates or explain what prevented timely filing throughout the 454-day period.

pp. 3–4, 13–14

Applying the cited principles, the Court held that these assertions amounted to an excuse rather than a bona fide explanation and did not establish sufficient cause.

pp. 13–14

It therefore found no basis to exercise discretion in favour of condonation.

pp. 13–14