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

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 23 November 2022 in L.A.C. No. 160/2020.

The appeal was filed on 20 January 2025, with a delay of 729 days. The appellant sought condonation of delay by I.A. No. 01/2026, relying principally on administrative reasons and movement of files.

Under the principles governing condonation of delay, the applicant must establish a reasonable, satisfactory, and bona fide cause that explains the delay; the length of delay may also be relevant. Government authorities receive no automatic or special indulgence and must demonstrate diligence and accountability.

In Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, the Supreme Court emphasized that public interest does not justify routinely excusing governmental negligence, and that administrative lethargy or laxity is not sufficient cause.

The Court also relied on State of Odisha v. Managing Committee of Namatara Girls High School, 2026 SCC OnLine SC 191, which held that condonation is discretionary and an excuse, rather than a genuine explanation, does not warrant relief.

The Court noted that the appeal was brought under Section 74(1) of the 2013 Act.

The affidavit gave general explanations based on file movement and administrative approvals but did not provide relevant dates or account for the entire period of delay. The Court found that it did not show any bona fide effort to file within the limitation period and was an excuse rather than a satisfactory explanation.

Applying the cited Supreme Court principles, the Court held that administrative delay and inter-departmental correspondence were insufficient to establish cause for condonation.

Pending interlocutory applications, if any, were disposed of.