Chhattisgarh High Court

Financial hardship and ignorance of law do not constitute sufficient cause for condoning inordinate delay.

SHEETAL VERMA vs CHHABIRAM VERMA

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

Facts

The Applicant sought to challenge an order dated 21.09.2022 passed by the Family Court, Bemetara, which rejected her maintenance application

Source reference: para 2

The Family Court had ruled against the Applicant because she was living separately without sufficient cause and was receiving maintenance from a previous husband, rendering her capable of self-maintenance

Source reference: para 2

The present criminal revision was filed with a delay of 1169 days

Source reference: para 1

The Applicant filed an application (I.A. No. 01 of 2026) to condone this delay, citing her weak financial condition, the time required to arrange funds, and her lack of acquaintance with legal procedures

Source reference: para 2
02

Issues

1. Whether the delay of approximately 1169 days in preferring the criminal revision petition deserves to be condoned under the standard of "sufficient cause."

Source reference: para 4
03

Law Applied

The Court relied on the principle that "sufficient cause" for condonation of delay must be an adequate reason that prevents a party from approaching the Court within the limitation period, as established in Majji Sannemma v. Reddy Sridevi (2021)

Source reference: para 5

discretion to condone delay must be exercised judiciously and not as a matter of generosity [State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932)]

Source reference: para 5

"sufficient cause" must be traced to circumstances arising within the prescribed limitation period, rather than events occurring after its expiry [Ajit Singh Thakur Singh v. State of Gujarat (1981)]

Source reference: para 5, sub-para 7
04

Reasoning

The Court found the delay of 1169 days to be "grossly inordinate"

Source reference: para 7

It evaluated the Applicant's justifications—poverty and lack of legal knowledge—and determined that while they may evoke sympathy, they do not constitute "sufficient cause" in the eyes of the law

Source reference: para 7

The Court reasoned that ignorance of the law and financial hardship do not overlook negligence or inaction, nor do they justify depriving the opposite party of the finality gained through the statute of limitation

Source reference: para 7

the Applicant remained inactive for a substantial period and failed to identify any specific circumstance within the initial limitation period that prevented her from filing the petition

Source reference: para 8

the explanation offered was unsatisfactory and failed to meet the judicial threshold for condonation

Source reference: para 9
05

Holding

The Court rejected the application for condonation of delay (I.A. No. 01 of 2026)

the criminal revision petition was dismissed as being hopelessly barred by limitation and laches

Source reference: para 9
Chhattisgarh High Court

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SHEETAL VERMAvsCHHABIRAM VERMA

Chhattisgarh High Court · April 01, 2026

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