Ignorance of Law and Lack of Diligence Do Not Constitute Sufficient Cause for Condoning Inordinate Delay.

The appellants (claimants) filed an appeal seeking enhancement of a compensation award of ₹15,69,632/- with 9% interest, passed by the 10th Additional Motor Accident Claims Tribunal, Bilaspur, on 24.01.2023.

The appeal was preferred on 19.12.2023, resulting in a delay of 231 days.

The appellants moved I.A. No. 01 for condonation of delay, citing their status as poor villagers and their ignorance of the law of limitation.

The respondent Insurance Company opposed the application, arguing a lack of "sufficient cause".

1. Whether the ignorance of the law of limitation and the socio-economic status of the appellants constitute "sufficient cause" to condone an inordinate delay under the Limitation Act.

The Court applied the principle that "ignorance of law is no excuse" to condone delay.

It primarily relied on the precedent set by the Hon’ble Supreme Court in H. Guruswamy & Ors. v. A. Krishnaiah [2025] 1 SCR 764, which established that concepts like "liberal approach" or "justice-oriented approach" cannot be used to frustrate the substantive law of limitation or excuse a party's own gross negligence and inaction.

The court further noted that the length of delay is a relevant factor and the bona fides of the explanation must be tested before considering the merits of the case.

The Court found that the appellants failed to provide a factual timeline, such as the dates they applied for or received the certified copy of the award, or when they first approached counsel.

The Court reasoned that the appellants remained inactive for 231 days, indicating a lack of diligence rather than a bona fide impediment.

Applying the H. Guruswamy precedent, the Court observed that rules of limitation are based on public policy and equity, and courts cannot keep the "Sword of Damocles" hanging over a litigant indefinitely due to the opposing party’s negligence.

Since the explanation offered was found to be vague and insufficient, the Court declined to adopt a "liberal approach" to bypass the statutory period.

Consequently, the appeal was dismissed as barred by limitation.

No costs were awarded.