Article 227 review cannot disturb concurrent rejection of delay condonation absent perversity or jurisdictional error.

The insured motorcycle’s registered owner, Sahdev Markam, died in an accident on 24 February 2021. His claim under the policy’s compulsory personal-accident cover was repudiated, and the respondents’ consumer complaint was partly allowed by the District Commission on 28 March 2024

The insurer’s first appeal, delayed by 132 days, was dismissed by the State Commission on 3 October 2024 after it declined to condone the delay. The insurer’s second appeal before the National Commission, filed 254 days late, was dismissed on 12 August 2025. The insurer then invoked Article 227, seeking remittal for a decision on the merits; the High Court noted that the writ petition was itself filed more than a year after the National Commission’s order

1. Whether the High Court should exercise its supervisory jurisdiction under Article 227 to interfere with the consumer fora’s concurrent refusal to condone the delays and dismissal of the appeals

2. Whether the insurer’s explanation of procedural delay in obtaining sanction and legal advice established sufficient cause for condonation

Article 227 confers limited supervisory, not appellate, jurisdiction; interference is warranted in cases of jurisdictional error, patent perversity, manifest illegality, or serious failure of justice, and the High Court may not reappreciate facts merely to substitute its view

The Court applied this principle as stated in Garment Craft v. Prakash Chand Goel, (2022) 4 SCC 181, including its discussion of Estralla Rubber v. Dass Estate (P) Ltd.

The Court also noted that the National Commission had considered Sheo Raj Singh (deceased) through Legal Representative v. Union of India, (2023) 10 SCC 531; Esha Bhattacharjee v. Raghunathpur Nafar Academy, (2013) 12 SCC 649; Popat Bahiru Govardhane v. Land Acquisition Officer, (2013) 10 SCC 765; and Bappanand Narshimman Annu v. Hirmanidevi G.S. Gupta, 2016 SCC OnLine NCDRC 2605, in assessing whether the delays were adequately explained

Section 51(1) of the Consumer Protection Act, 2019, was invoked by the insurer as permitting an appeal to be entertained after the prescribed period on sufficient cause being shown

The High Court found that both consumer fora had considered and rejected the insurer’s explanation that internal processes to obtain sanction and legal advice caused the delay, and had concluded that sufficient cause was not established

It saw no jurisdictional error, procedural irregularity, perversity, or manifest injustice in those concurrent findings

The insurer’s desire to have the underlying insurance dispute decided on its merits did not justify overlooking limitation, particularly given the unexplained delay in filing the second appeal and the further delay before approaching the High Court

dismissed the writ petition, leaving undisturbed the National Commission’s order dismissing the second appeal and the State Commission’s order refusing to condone the delay in the first appeal