Condonation of delay requires sufficient cause arising before the statutory limitation period expires.

The applicant, Satish Samalia, filed a criminal revision petition challenging an impugned order dated 13.11.2025.

The revision was filed with a delay of 52 days beyond the prescribed limitation period.

Along with the revision, the applicant filed I.A. No. 02 of 2026, an application for condonation of delay, contending that the time was consumed in obtaining the certified copy of the order and preparing the filing.

The applicant claimed the delay was bona fide and not intentional.

1. Whether the delay of approximately 52 days in preferring the criminal revision petition deserves to be condoned based on the explanation provided.

The court relied on the principles of limitation and "sufficient cause" as interpreted by the Supreme Court of India.

It primarily applied the recent precedent in State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932), which dictates that discretion to condone delay must be exercised judiciously and not as a matter of generosity.

The court cited Basawaraj v. Special Land Acquisition Officer (2013) to establish that negligence or inaction cannot constitute "sufficient cause".

Furthermore, it applied the doctrine from Ajit Singh Thakur Singh v. State of Gujarat (1981), which requires that the "sufficient cause" for not filing must be traced to events occurring within the period of limitation, rather than circumstances arising after the period has already expired.

The Court observed that the statutory period of limitation is founded on public policy to ensure finality in litigation and cannot be waived lightly.

In applying the cited precedents to the present facts, the Court found the applicant's explanation—that the delay was due to the time taken for obtaining a certified copy and drafting—legally insufficient.

The Court noted that the applicant failed to demonstrate any specific circumstance occurring within the limitation period that prevented him from approaching the Court on time.

Following the rigors of the "sufficient cause" test, the Court determined that the delay was "grossly inordinate" and that condoning it would cause prejudice to the opposite party's accrued rights under the law of limitation.

The Court rejected I.A. No. 02 of 2026 for condonation of delay.

Consequently, the criminal revision petition was dismissed as being barred by limitation and laches.