Administrative lethargy and file movement do not constitute sufficient cause to condone the State’s 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 12 September 2023 in LAC No. 2616/2020.

The appeal was filed on 4 March 2025, with a delay of 350 days.

The appellant sought condonation of delay by I.A. No. 1/2026, supported by an affidavit attributing the delay mainly to administrative processes and movement of files.

The High Court found that the affidavit did not provide relevant dates or explain the delay adequately.

Section 74(1) of the 2013 Act provides for an appeal from the Authority’s award.

Under the principles governing condonation of delay, including Section 5 of the Limitation Act, 1963, the applicant must establish a reasonable and satisfactory cause covering the period of delay; Section 3 reflects the requirement that proceedings barred by limitation be dismissed.

In Shivamma v. Karnataka Housing Board, 2025 SCC OnLine SC 1969, the Supreme Court held that the State receives no automatic indulgence for delay, administrative lethargy is not sufficient cause, and the explanation must demonstrate bona fide diligence.

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

The appellant’s affidavit relied largely on file movement and administrative approvals, but supplied no relevant dates or account of what prevented timely filing.

It therefore neither explained the entire period of delay nor demonstrated bona fide efforts to appeal within the limitation period.

Applying the cited Supreme Court principles, the Court held that generic administrative reasons do not constitute sufficient cause, including where the applicant is a government authority.

As the delay application failed, the Court did not proceed to determine the merits of the appeal.

Consequently, the appeal was dismissed; pending applications, if any, were disposed of.