### Financial Hardship Failing Specific Substantiation Does Not Constitute "Sufficient Cause" for Inordinate Delay in Filing Appeal

The Appellant, whose father was a Constable, applied for a compassionate appointment following his father's demise.

This application was rejected, leading the Appellant to file a writ petition (W.P.(S) No. 2151/2024), which was dismissed by a Single Judge on 03.05.2024.

The Appellant preferred the present writ appeal against said dismissal after a delay of 637 days.

The Appellant cited financial hardship and lack of resources as the primary reasons for the delay.

Whether the Appellant established "sufficient cause" to condone the inordinate delay of 637 days in filing the writ appeal under the Chhattisgarh High Court (Appeal to Division Bench) Act, 2006.

Section 2(1) of the Chhattisgarh High Court (Appeal to Division Bench) Act, 2006, which prescribes a 45-day limitation period for appeals.

State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932), which establishes that limitation must be applied with rigour and "sufficient cause" requires an adequate reason that prevented the party from approaching the court within the limitation period—not events occurring after its expiry.

Principles from Majji Sannemma v. Reddy Sridevi and Basawaraj v. Special Land Acquisition Officer, holding that discretionary power to condone delay cannot be exercised where there is negligence, inaction, or lack of bona fides.

The Court examined the Appellant’s justification of "financial constraints" and "lack of resources" and found the explanation vague and lacking specific supporting material.

Applying the Ramkumar Choudhary standard, the Court noted that a party seeking condonation must explain why they were unable to institute proceedings specifically between the 1st and the 90th/45th day of the limitation period.

The Court observed that the Appellant failed to provide a cogent and satisfactory explanation covering the entire period of delay, particularly the timeframe within the prescribed limitation.

It reasoned that condoning such an inordinate delay without a "sufficient cause" would defeat the object of the law of limitation and allow for the revival of stale claims at a litigant's whim.

Consequently, the Court rejected I.A. No. 01 of 2026 (the application for condonation of delay) and the writ appeal was dismissed solely on the grounds of delay and laches without an inquiry into the merits of the case.