Bureaucratic procedural delays do not constitute sufficient cause for condoning inordinate delay in State-filed appeals.

The State of Chhattisgarh filed an application for grant of leave to appeal against the judgment of acquittal dated 01.05.2024 passed in Special Case (POCSO) No. 10/2023

The Trial Court had acquitted the respondent of charges under Section 354 of the Indian Penal Code (IPC) and Section 8 of the Protection of Children from Sexual Offences (POCSO) Act, 2012

The State’s petition was filed with a delay of 350 days

The State contended that the delay was bona fide and resulted from the multi-functional nature of government machinery, involving necessary departmental formalities and the processing of files between the Law & Legislative Affairs Department and the Office of the Advocate General

Whether the State demonstrated "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of a 350-day delay in filing the petition for leave to appeal

The court primarily considered the principles of condonation of delay under the Limitation Act

It relied on the Supreme Court's ruling in Postmaster General v. Living Media India Limited (2012), which established that the government cannot claim a separate, longer limitation period and that "procedural red-tape" is not a valid excuse in the age of modern technology

The court further applied the doctrine from State of Madhya Pradesh v. Ramkumar Choudhary (2024), which held that "sufficient cause" must be established through evidence of diligence and that the cause for delay must be traced to events occurring within the original limitation period

The Court noted that while a liberal approach may be taken in the absence of gross negligence, the State is under a special obligation to perform its duties with diligence

The Court found the State’s explanation—citing general "departmental formalities" and the processing of a proposal by the Law & Legislative Affairs Department—to be vague and lacking in specificity

Referring to Ramkumar Choudhary, the Court emphasized that any event cited as a "sufficient cause" must have occurred before the limitation period expired to explain the failure to file on time

The Court reasoned that the State failed to provide a cogent or acceptable reason for the 350-day delay, concluding that the delay was a result of a lackadaisical attitude rather than a bona fide hindrance

The Court declined to exercise its discretionary power to condone the 350-day delay, stating that condonation is an exception and not an anticipated benefit for government departments

Consequently, the petition seeking leave to appeal was rejected on the grounds of delay and laches