Administrative lethargy and routine bureaucratic file movement do not constitute sufficient cause for condoning inordinate delay.

The Appellants (State authorities) filed a Letters Patent Appeal (L.P.A.) challenging the Single Judge’s judgment dated 25.07.2023

Along with the appeal, I.A. No. 3451 of 2026 was filed seeking condonation of a 762-day delay

The Appellants attributed the delay to routine departmental procedures, including file movements, legal opinions, and internal processing

Notably, the first step toward filing the appeal was taken only after the Respondent initiated contempt proceedings

There were two specific periods of total inactivity lasting approximately nine and ten months, respectively

1. Whether the Appellants demonstrated "sufficient cause" under Section 5 of the Limitation Act to condone the 762-day delay in filing the appeal

2. Whether administrative lethargy and bureaucratic file movement entitle a Government department to a special or extended period of limitation

The court applied Section 5 of the Limitation Act, which requires the applicant to account for each period of delay with specific, cogent, and satisfactory reasons

Government departments cannot claim special treatment regarding limitation and that "impersonal machinery" is no excuse in the age of modern technology [Postmaster General v. Living Media India Ltd. (2012)]

merits of a case cannot override gross delay unless the explanation is bona fide [Union of India v. Jahangir Byramji Jeejeebhoy (2024)]

administrative lethargy does not constitute "sufficient cause" [Shivamma v. Karnataka Housing Board (2025)]

The court found that the Appellants failed to explain two significant gaps of nine and ten months during the 762-day delay

It observed that the Appellants merely recounted the "bureaucratic movement of files" without establishing the "sufficient cause" mandated by law

The court rejected the argument that a "good case on merits" should justify the delay, noting that rules of limitation are grounded in public policy and equity to ensure the finality of litigation

The Bench emphasized that constitutional courts must not become "surrogates for State laxity," as reopening matters after inordinate delays frustrates the rights of private litigants and subjects them to perpetual litigation

It dismissed I.A. No. 3451 of 2026, and consequently, the Letters Patent Appeal (L.P.A. No. 162 of 2026) was also disposed of as it did not survive the dismissal of the delay application