Ignorance of law and lack of legal advice do not constitute sufficient cause for condoning inordinate delay.

The applicant (husband) filed a criminal revision petition challenging an order dated 26.11.2024 passed by the Family Court, Durg, which granted monthly maintenance of Rs. 3,000 to the non-applicant (wife)

The revision was filed with a delay of 377 days

The applicant sought condonation of delay (I.A. No. 02 of 2026) on the grounds that he is a laborer, lacked legal awareness, was mentally distressed, and bona fide believed his wife would return to him following a decree for restitution of conjugal rights in his favor

Whether the delay of 377 days in preferring the criminal revision petition deserves to be condoned on the grounds of lack of legal awareness and a pending decree for restitution of conjugal rights.

The Court primarily applied the principles governing the condonation of delay under the Limitation Act, as interpreted by the Supreme Court in State of Madhya Pradesh v. Ramkumar Choudhary (2024)

It relied on the doctrine that "sufficient cause" requires an adequate reason preventing the party from approaching the court within the limitation period, and that discretion cannot be exercised liberally if negligence, inaction, or lack of bona fides is evident (Majji Sannemma v. Reddy Sridevi)

The Court further applied the rule from Ajit Singh Thakur Singh v. State of Gujarat (1981), establishing that sufficient cause must be traced to a circumstance arising within the period of limitation, not after its expiry

the court noted that ignorance of law and lack of legal advice do not constitute sufficient cause to override the statutory rigors of limitation

The Court observed that while the applicant’s status as a laborer and his belief regarding the restitution of conjugal rights were "plausible" reasons for sympathy, they did not satisfy the legal threshold for "sufficient cause"

The Court emphasized that the delay of 377 days was "grossly inordinate" and that the applicant remained inactive for a long period without justifying why he could not approach the Court within the initial 90-day window

Citing Union of India v. Jahangir Byramji Jeejeebhoy, the Court noted that limitation is founded on public policy and equity, and condoning such delays as a "matter of generosity" would cause undue prejudice to the opposite party who has gained a right through the finality of the lower court's order

The Court concluded that the applicant failed to prove reasonable diligence, rendering the delay non-deliberate but legally inexcusable

the Court rejected I.A. No. 02 of 2026 and dismissed the criminal revision petition as barred by limitation and laches