Administrative lethargy and file movement do not constitute sufficient cause to condone the State’s 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 17 November 2023 in LAC No. 48/2019.

The appeal was filed on 19 June 2025, with a delay of 520 days.

The appellants sought condonation by I.A. No. 01/2026, filed on 17 March 2026, relying principally on administrative reasons and movement of files.

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

Under Section 74(1) of the 2013 Act, the appellants brought the appeal against the land-acquisition award.

In considering the delay application, 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 litigant seeking condonation must provide a reasonable and satisfactory explanation for the delay; the explanation must be bona fide and account for the period of delay; and the State receives no automatic or special indulgence, since administrative lethargy and file movement do not, without more, establish sufficient cause.

The Court also relied on the limitation principles quoted from Basawaraj v. Special Land Acquisition Officer: limitation must be applied as prescribed, and courts cannot extend it on equitable grounds absent sufficient cause.

The affidavit relied on general assertions about administrative processes and file movement but provided no relevant dates or account of what prevented the appellants from filing within the prescribed period.

The Court held that these assertions neither explained the entire delay nor demonstrated bona fide diligence.

Applying the Supreme Court’s guidance, it treated the stated reasons as an excuse rather than a sufficient explanation and found no basis to exercise discretion in the appellants’ favour.

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