Chhattisgarh High Court

Condonation of inordinate delay requires demonstration of sufficient cause and diligence within the limitation period.

Y. SHRINIVAS MURTHY vs THE STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant challenged the order dated 27.06.2024 passed by a learned Single Judge in WPS No. 4337 of 2014, which dismissed the appellant's writ petition

Source reference: para 2

The present writ appeal was filed with an inordinate delay of 554 days

Source reference: para 3

The appellant filed I.A. No. 1 for condonation of delay, citing his elderly father's medical ailments, specifically anxiety and abdominal pain, as the reason for the delay

Source reference: para 9

The respondents opposed the application, arguing a lack of cogent explanation for the delay and laches

Source reference: para 4
02

Issues

Whether the delay of 554 days in preferring the writ appeal deserves to be condoned under the parameter of "sufficient cause"

Source reference: para 6
03

Law Applied

The Court primarily relied on the principle of "sufficient cause" as defined in Basawaraj v. Special Land Acquisition Officer, which mandates that an applicant must provide adequate reasons that prevented timely approach to the court; negligence or inaction precludes condonation

Source reference: para 7

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

Source reference: para 5, 7

the Court referred to Ajit Singh Thakur Singh v. State of Gujarat, establishing that the "sufficient cause" must be traced to a circumstance arising within the original period of limitation

Source reference: para 7
04

Reasoning

The Court found that the appellant failed to provide a plausible or cogent explanation for the 554-day delay

Source reference: para 3

Regarding the medical grounds, the Court observed that while the father's illness may invoke sympathy, it did not constitute "sufficient cause" in the eye of the law, as there was no evidence that the father was bedridden or in a condition critical enough to prevent the appellant from filing the appeal

Source reference: para 9

The Court noted that the appellant remained inactive for a substantial period and only sought to revive the claim after a long interval, which indicates a lack of diligence and bona fides

Source reference: para 10

Adhering to the principle that the law of limitation is based on public policy and equity, the Court determined that the valuable rights accruing to the respondent due to the lapse of time could not be disregarded without a demonstrably sufficient cause arising within the limitation period

Source reference: para 10, 11
05

Holding

The Court held that no case for condonation of delay was made out as the appellant failed to explain the inordinate delay satisfactorily

Consequently, I.A. No. 1 was rejected, and the writ appeal was dismissed as hopelessly barred by limitation and the doctrine of delay and laches

Source reference: para 11
Chhattisgarh High Court

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Y. SHRINIVAS MURTHYvsTHE STATE OF CHHATTISGARH

Chhattisgarh High Court · April 07, 2026

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