Beneficial legislation does not justify condoning an inordinate, inadequately explained appeal delay.

The appellants, whose son died in a road-traffic accident in 2012, sought compensation before the Motor Accident Claims Tribunal. The Tribunal awarded them ₹3,00,000 on 12 September 2014, which they received

In 2024, they filed an appeal under Section 173(1) of the Motor Vehicles Act seeking enhancement, accompanied by an application under Section 5 of the Limitation Act to condone a stated delay of 2,615 days.

They attributed the delay to bereavement, the second appellant’s depression and health problems, their lack of education and guidance, and their former counsel’s failure to inform them of the right to appeal.

Respondent No. 2 opposed condonation, arguing that the explanation was vague and did not account for the intervening period.

1. Whether the appellants established sufficient cause to condone the delay in filing the appeal

Section 5 of the Limitation Act empowers a court to condone delay where sufficient cause is shown, but the discretion is not automatic; the explanation must be assessed for bona fides and adequacy.

The Court relied on Thirunagalingam v. Lingeshwarn and another (Civil Appeal No. … of 2025, arising out of SLP(C) No. 17575 of 2023; case number incomplete in the judgment), including the principle that limitation cannot be extended on equitable grounds without a proper explanation.

It also relied on Pathapati Subba Reddy (D) by L.Rs. & Ors. v. The Special Deputy Collector (LA), 2024 INSC 286, for the principles that limitation serves public policy, a liberal approach cannot defeat the statutory scheme, and even sufficient cause does not invariably require condonation where factors such as inordinate delay, negligence, or want of due diligence weigh against it.

The beneficial character of the Motor Vehicles Act does not, by itself, excuse unexplained delay.

The Court found that the appellants had not provided a satisfactory account of the lengthy period between the Tribunal’s award and the 2024 appeal. Their assertions of shock, depression, health problems, and ignorance of the right to appeal were general and unsupported by medical records or other cogent material.

The Court also considered that they had pursued the original claim through counsel and had received the compensation awarded, making their plea of ignorance insufficient to explain the prolonged inaction. It therefore held that the beneficial nature of the legislation could not substitute for proof of sufficient cause.

It dismissed I.A. No. 1/2024 seeking condonation of delay and, consequently, dismissed the appeal as barred by limitation.