### Government Departments Must Demonstrate Sufficient Cause and Diligence to Justify Condonation of Delay in Filing Appeals

The State of Chhattisgarh sought leave to appeal against a judgment dated 20.01.2023, passed by the Additional Sessions Judge, Baikunthpur, which acquitted the respondent of charges under Sections 307 and 302 of the IPC.

The State filed the instant petition with a delay of 74 days beyond the prescribed limitation period.

The State attributed this delay to the fulfillment of departmental formalities and the inherent procedural requirements of Government machinery.

Whether the administrative delays inherent in Government machinery constitute "sufficient cause" under Section 5 of the Limitation Act to condone a 74-day delay in filing an acquittal appeal.

The Court applied Section 5 of the Limitation Act regarding the condonation of delay upon showing "sufficient cause".

It relied on *Postmaster General v. Living Media India Limited* (2012) 3 SCC 563, which established that Government departments are not entitled to a separate or more liberal period of limitation and must perform duties with diligence.

It further cited *State of Madhya Pradesh v. Ramkumar Choudhary* (2024) INSC 932 and *Ajit Singh Thakur Singh v. State of Gujarat* (1981) SC 733, which clarify that "sufficient cause" must be traced to circumstances arising *within* the original limitation period and that negligence or inaction precludes exercise of judicial discretion.

The Court reasoned that while the appellate court has wide powers to re-appreciate evidence in acquittal cases, such powers cannot be invoked if the petition is barred by limitation without a valid explanation.

The Court rejected the State's plea that "bureaucratic methodology" or "procedural red-tape" justifies delay, noting that modern technology renders such traditional excuses unacceptable.

Applying the *Ramkumar Choudhary* precedent, the Court emphasized that the State failed to demonstrate a specific event within the first 90 days that prevented timely filing.

The explanation provided was deemed "vague" and "non-specific," failing the "sufficient cause" test required to trigger the Court's discretionary power.

Consequently, the application for condonation of delay was rejected, and the petition for leave to appeal was dismissed as time-barred.