Administrative lethargy and internal departmental procedures do not constitute sufficient cause for condoning inordinate delay.

The Appellant, Commissioner of the Municipal Corporation Bhopal, filed a miscellaneous appeal challenging an award passed by the Claims Tribunal.

The appeal was filed with a delay of 758 days.

The Appellant filed I.A. No. 18128/2024 seeking condonation of this delay, citing administrative procedures, the need for legal opinion from counsel, and the requirement for sanctions/permissions from higher authorities due to its status as a government body.

1. Whether the administrative delays and procedural requirements of a government body constitute "sufficient cause" for the condonation of an inordinate delay of 758 days under the law of limitation.

The court applied the principle that "delay defeats equity" and that legal remedies are for the vigilant, not those who "slumber over their rights," as established in Pundlik Jalam Patil v. Executive Engineer, Jalgaon Medium Project (2008) 17 SCC 448.

Majji Sannemma @ Sanyasirao v. Reddy Sridevi and Others AIR 2022 SC 332.

Shivamma (dead) by LRs v. Karnataka Housing Board and others (Civil Appeal No. 11794/2025), which held that administrative lethargy, laxity, or "lackadaisical attitude" of State agencies cannot serve as sufficient grounds for condoning delay.

The Court rejected the Appellant’s justification that the 758-day delay was bona fide due to internal departmental procedures and the pursuit of legal opinion.

Relying on Supreme Court precedents, the Court reasoned that the State machinery must establish that it acted with bona fides and remained vigilant.

The Court observed that constitutional courts should not act as "surrogates for State laxity," as doing so frustrates the fruits of decrees obtained by private litigants.

In this case, the Court found that the Appellant failed to provide a reasonable or proper explanation for the extensive delay, characterizing the grounds as "frivolous and superficial".

Consequently, I.A. No. 18128/2024 for condonation of delay was dismissed.

Resultantly, the Miscellaneous Appeal was also dismissed as barred by limitation.

All pending interlocutory applications were closed.