Governmental procedural red-tape and administrative lethargy do not constitute "sufficient cause" for condoning inordinate delay.

The applicant (Special Land Acquisition Officer) filed a batch of civil applications under Section 5 of the Limitation Act, 1963, seeking to condone a delay of 1225 days in preferring First Appeals against a common judgment and award dated 11.05.2022 passed by the Ld. Special Judge (L.A.Q.), Ahmedabad (Rural).

The applicant contended that the delay was procedural, arising from inter-departmental correspondence, administrative approvals, and a cautious approach to ensure accurate filing.

The respondents opposed the applications, arguing that the grounds raised were vague, evasive, and failed to establish "sufficient cause" as required by law.

1. Whether the applicant established "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of an inordinate delay of 1225 days.

2. Whether the "liberal approach" typically afforded to the State in procedural delays can be invoked to override the substantive law of limitation in the absence of due diligence.

Section 5 of the Limitation Act, 1963, which permits the admission of an appeal after the prescribed period if the appellant satisfies the court of "sufficient cause".

Pathapati Subba Reddy v. Special Deputy Collector (LA) (2024) 12 SCC 336, which held that while Section 5 should be construed liberally to advance justice, it cannot be used to defeat the substantive law of limitation or reward negligence.

State of Odisha v. Managing Committee of Namatara Girls High Schools (2026 INSC 148) and Office of the Chief Post Master General v. Living Media India Ltd. (2012) 3 SCC 563, establishing that the State cannot claim special treatment based on "bureaucratic methodology" or "procedural red-tape" in the era of modern technology.

The court found that the applicant failed to provide a satisfactory explanation for the "huge delay" of 1225 days.

Although the applicant detailed a timeline of communications between August 2022 and September 2025, the court characterized these reasons as "lame excuses" rather than a valid "explanation".

The court reasoned that the "liberal approach" is conditional upon the absence of negligence or inaction; here, the applicant exhibited a lack of due diligence.

Following Living Media India Ltd., the court rejected the plea of "impersonal machinery," noting that the law of limitation binds the Government equally and that condonation is an exception, not an "anticipated benefit" for state departments.

The court dismissed all civil applications for condonation of delay and refused the registration of the First Appeals.