Government departments must show "sufficient cause" and diligence to merit condonation of inordinate delay.

The State of Chhattisgarh (Appellants) filed a Writ Appeal challenging the order of a learned Single Judge dated 02.05.2025 in WPS No. 2315 of 2017

The appeal was filed with a delay of 234 days beyond the prescribed limitation period

The Appellants filed I.A. No. 1 of 2026 seeking condonation of delay, citing administrative procedural requirements, including obtaining legal opinions (03.09.2025), seeking departmental sanction (08.01.2026), and appointing an Officer-in-Charge (04.02.2026)

The Appellants contended that as a multi-functional body, departmental formalities take time and the delay was bona fide

Whether the administrative "red-tape" and departmental formalities of the State constitute "sufficient cause" for condoning an inordinate delay of 234 days under the law of limitation

The Court applied the principle that the law of limitation binds the Government and private litigants equally

It relied on *Postmaster General v. Living Media India Limited* (2012) 3 SCC 563, which held that government departments have a special obligation of diligence and cannot claim "procedural red-tape" as a valid excuse for delay

The Court further applied *State of Madhya Pradesh v. Ramkumar Choudhary* (2024 INSC 932), establishing that "sufficient cause" must be traced to circumstances arising *within* the limitation period, rather than subsequent events

Finally, it referenced *Shivamma v. Karnataka Housing Board* (2025 INSC 1104), cautioning High Courts against becoming "surrogates for State laxity"

The Court scrutinized the chronological explanation provided by the State and found it lacked specificity and "sufficient cause"

It reasoned that modern technology renders the excuse of "impersonal machinery" and "inherited bureaucratic methodology" unacceptable

The Court observed that the State failed to explain why it was unable to act within the initial period of limitation, noting that events occurring after the expiry of the 90-day period (such as sanctions obtained months later) do not justify the initial default

The Court emphasized that condonation is an exception and not a "legitimizing effect" for callous attitudes or administrative lethargy

The Court refused to exercise its discretionary power to condone the delay, stating that the State was not reasonably diligent

Consequently, I.A. No. 1 of 2026 was rejected, and the Writ Appeal was dismissed on the grounds of delay and laches