Administrative lethargy and internal procedural delays do not constitute sufficient cause for condonation of inordinate delay.

The petitioner, National Insurance Co. Ltd., filed a review petition seeking to challenge an earlier order involving a Motor Accident Claims Tribunal award. The petition was filed with a delay of 362 days

The petitioner attributed the delay to internal administrative procedures, including obtaining legal opinions regarding filing a Special Leave Petition (SLP), the misplacement of the file between regional offices (Bhopal, Indore, and Delhi), and its subsequent recovery on 22.03.2025

The petitioner further sought review on the grounds that the Co-ordinate Bench incorrectly awarded compensation for certain heads and erroneously assessed permanent disability at 40%

1. Whether the administrative delays and misplacement of files by a State/Corporate entity constitute "sufficient cause" for the condonation of a 362-day delay

2. Whether the grounds challenging the quantum of compensation and assessment of disability fall within the narrow scope of review jurisdiction

The Court applied the principle that delay cannot be condoned in a routine manner and requires a satisfactory explanation for the entire period of delay

Pundlik Jalam Patil v. Executive Engineer, Jalgaon Medium Project (2008) 17 SCC 448: holding that "delay defeats equity" and courts assist the vigilant, not those who "slumber over their rights"

Majji Sannemma @ Sanyasirao v. Reddy Sridevi AIR 2022 SC 332 and Shivamma (dead) v. Karnataka Housing Board (Civil Appeal No. 11794/2025): administrative lethargy, laxity, or "lackadaisical attitude" of State instrumentalities are not frivolous grounds for condonation

jurisdiction is limited to "errors apparent on the face of the record" or discovery of new evidence, per Order 47 Rule 1 of the CPC

The Court found the petitioner’s explanation regarding internal file movement and misplacement to be "general in nature" and indicative of a lack of due diligence

Reaffirming the Supreme Court’s stance in Shivamma, the Court noted that State agencies cannot be granted legitimizing effect for callous attitudes or administrative lethargy

the Court observed that the petitioner's grievances regarding the assessment of disability and specific compensation heads (attendant charges, diet, etc.) were essentially appellate grounds rather than "errors apparent on the face of the record"

Since the petitioner failed to show any discovery of new matter or a patent legal error, the review jurisdiction could not be invoked as a substitute for an appeal

The Review Petition was dismissed both on the grounds of limitation and on merits, as the petitioner failed to satisfy the narrow criteria for review jurisdiction. No costs were awarded.