Administrative red tape is not sufficient cause for condoning delay in filing State appeals.

The State of Chhattisgarh sought leave to appeal against a judgment of acquittal dated 04.03.2023, passed by the Additional Sessions Judge, Kabirdham

The State filed an application for condonation of delay (I.A. No. 01 of 2023), as the petition was filed with a delay of 105 days beyond the prescribed limitation period

The State attributed the delay to "departmental formalities" and the "working of the Government machinery," specifically citing the time taken for the Law & Legislative Affairs Department to send a proposal to the Advocate General’s office and the subsequent processing of documents

Whether the State provided "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of a 105-day delay in filing an application for leave to appeal an acquittal

Section 5 of the Limitation Act regarding the requirement of "sufficient cause" for condoning delays

government departments must perform duties with diligence and cannot claim administrative "red-tape" as a valid ground for condonation

limitation binds the Government equally to private litigants and that "sufficient cause" must be traced to events arising within the limitation period, rather than subsequent administrative movements

The Court examined the State's justification, which relied on the sequence of departmental communications between 24.08.2023 and the filing date

The Court found this explanation lacked specificity and failed to demonstrate why the State was prevented from acting within the initial limitation period

Applying the Postmaster General and Ramkumar Choudhary doctrines, the Court reasoned that condonation is an exception and cannot be used as an "anticipated benefit" for government entities

The Court emphasized that "bureaucratic methodology" and "impersonal machinery" are no longer acceptable excuses in the age of modern technology

Since the State provided only a chronological list of administrative steps without a "plausible or acceptable" reason for the lapse, the Court held that the State acted with a lack of due diligence

the Criminal Miscellaneous Petition seeking leave to appeal was rejected on the grounds of delay and laches