Bureaucratic file movement does not constitute "sufficient cause" for condoning significant delays in government appeals.

The respondent, an employee of appellant no. 1 since 2009, was nominated for a professional training program in Chandigarh.

While traveling from Meerut Cantt to Chandigarh on 12.12.2010, he met with a road accident, resulting in 85% permanent disability as assessed by a Medical Board.

The respondent filed a claim under Section 22 of the Employees’ Compensation Act, 1923.

On 31.05.2013, the Commissioner allowed the claim, awarding Rs. 5,23,586/- with 12% interest.

The appellants challenged this order after a delay of 1,241 days, citing administrative movement of files and internal approvals as the cause for delay.

1. Whether the substantial delay of 1,241 days in filing the appeal can be condoned under Section 5 of the Limitation Act, 1963.

2. Whether a pre-existing disability disentitles an employee from claiming compensation for injuries sustained in a subsequent accident under the Employees’ Compensation Act.

3. Whether the order was void for lack of jurisdiction due to the Commissioner’s transfer between districts during the proceedings.

The court applied Section 5 of the Limitation Act, 1963, regarding the condonation of delay, and the Employees’ Compensation Act, 1923, specifically Section 22 for claims and Section 21 regarding the transfer of proceedings.

Government is bound by the law of limitation and does not enjoy preferential treatment for bureaucratic delays as per Postmaster General v. Living Media India Ltd.

The mere "movement of files" is not a sufficient cause for condonation as held in State of Madhya Pradesh v. Bherulal.

The Court first addressed the 1,241-day delay, observing that the appellants provided no substantive explanation other than describing internal bureaucratic processes.

Relying on Postmaster General, the Court held that the Government cannot treat condonation as an "anticipated benefit" and failed to show diligence.

On the merits, the Court rejected the argument that the respondent's pre-existing 65% disability barred him from claiming compensation for the new 85% disability assessment, reasoning that the Act does not contemplate denial of compensation for subsequent accidents simply because of a prior condition.

Regarding jurisdiction, the Court noted that Section 21 of the Act expressly permits the transfer of proceedings and found the appellants' challenge to the Commissioner's authority to be a "bald plea" unsupported by evidence.

The Court ordered the release of the deposited award amount with accrued interest to the respondent and directed the appellants to pay any remaining interest within four weeks.