Inconsistent conduct and filing of proceedings during alleged illness negate claims for condonation of delay.

The applicant sought a review of a High Court order dated May 13, 2025, which had dismissed his writ petition (WPLRT 65 of 2025) directed against a Land Reforms and Tenancy Tribunal (LRTT) order.

The Tribunal had refused to condone a delay in filing an application challenging a land vesting order.

The applicant contended that medical issues prevented timely filing and introduced a new medical certificate from a third doctor (Dr. Sumit Khotick) covering March 1, 2022, to December 10, 2022, asserting this was not previously available to his counsel.

1. Whether the applicant provided sufficient cause to review the previous order dismissing the writ petition on grounds of limitation and lack of explanation for specific periods of delay.

The Court applied the principles governing the review of judicial orders and the doctrine of "sufficient cause" for condonation of delay under the Limitation Act.

The court specifically considered the amnesty period granted by the Hon’ble Supreme Court regarding limitation during the COVID-19 pandemic.

For a review to be maintainable, there must be a discovery of new and important matter or evidence which, after the exercise of due diligence, was not within the knowledge of the petitioner, or an error apparent on the face of the record.

The Court evaluated the applicant's medical evidence and found it inconsistent with his actions. While the applicant relied on a new certificate from Dr. Sumit Khotick claiming illness from March 1, 2022, to December 10, 2022, the Court noted that the applicant was physically and legally capable of filing his Original Application before the Tribunal on July 15, 2022.

This contemporaneous action belied the claim that his medical condition prevented him from approaching the Tribunal during that specific window.

Further, the Court observed that despite claiming extensive medical treatment, the applicant did not seek medical reimbursement for these expenses.

The Court concluded that the newly produced documents failed to bridge the unexplained gaps in the limitation period previously identified, particularly the periods from January 29, 2020, to March 14, 2020, and the post-COVID period in 2022.

The Court dismissed RVW 276 of 2025 along with all connected applications, granting no relief to the applicant.