### Administrative Procedural Delays Do Not Constitute Sufficient Cause for Condoning Inordinate Delay by State Pathologies

The State of Chhattisgarh filed a writ appeal challenging an order passed by a learned Single Judge on 25.09.2024

There was a delay of 428 days in preferring the appeal

The Appellants contended that the delay was due to bona fide departmental procedures, including obtaining legal opinions (07.11.2025), seeking permission from the Law & Legislative Affairs Department (15.12.2025), and appointing an Officer-in-Charge (16.12.2025)

The Respondent opposed the application, noting that a batch of similar appeals had already been dismissed by the High Court and a subsequent Special Leave Petition (SLP) was dismissed by the Supreme Court on 07.11.2025 due to delay

1. Whether the administrative and procedural red-tape within government departments constitutes "sufficient cause" for condoning a significant delay in filing an appeal under Section 5 of the Limitation Act

The Court applied the rigors of the Limitation Act, emphasizing that the law binds the Government equally to private litigants

It relied on *Postmaster General v. Living Media India Limited (2012)*, which established that government departments cannot claim a separate period of limitation or cite "bureaucratic methodology" as an excuse for negligence

It further applied *State of Madhya Pradesh v. Ramkumar Choudhary (2024)* and *Shivamma v. Karnataka Housing Board (2025)*, which held that "sufficient cause" cannot be interpreted liberally in cases of callousness or lack of bona fides, and that courts should not act as surrogates for State laxity

The Court reasoned that the explanation provided—a sequence of internal dates for approvals and opinions—did not amount to a "sufficient cause" but rather highlighted a "callous and lackadaisical attitude"

The Court observed that while departments have a systematic approach, they often fail to act with due diligence, leading to enormous delays that prejudice the opposing party

It noted that the Appellants failed to prove they were reasonably diligent between the first and ninetieth day of the limitation period

Given that the Supreme Court had already dismissed an SLP in a similar matter on the grounds of delay, the High Court found no reason to exercise its discretionary power to condone the 428-day delay in this instance

The application for condonation of delay (I.A. No. 01 of 2026) was rejected, and consequently, the writ appeal was dismissed at the threshold on the grounds of delay and laches

No order as to costs was passed