Inordinate and unexplained delay cannot be condoned without establishing sufficient cause within the limitation period.

The applicant sought to challenge an order dated 26.07.2025 by filing a criminal revision petition before the High Court of Chhattisgarh.

The petition was filed with a delay of 117 days.

The applicant filed I.A. No. 01 of 2026 for condonation of delay, citing that she is an uneducated lady unaware of legal remedies and that her mother’s hospitalization for age-related ailments required her constant care during the limitation period.

1. Whether the delay of 117 days in preferring the criminal revision deserves to be condoned based on the grounds of "sufficient cause".

The court applied the "sufficient cause" test under the law of limitation.

The court primarily relied on the Supreme Court’s ruling in *State of Madhya Pradesh v. Ramkumar Choudhary* (2024 INSC 932).

This precedent establishes that limitation must be applied with rigor and that "sufficient cause" requires an adequate reason preventing the party from approaching the court within the prescribed period.

It further incorporates principles from *Majji Sannemma v. Reddy Sridevi* and *Ajay Dabra v. Pyare Ram*, establishing that negligence, inaction, or lack of bona fides precludes condonation.

The court also noted *Ajit Singh Thakur Singh v. State of Gujarat*, which mandates that sufficient cause must be traced to circumstances arising *within* the period of limitation.

The court examined whether the applicant’s reasons met the threshold of "sufficient cause."

It determined that the applicant failed to demonstrate a specific circumstance arising within the 90-day limitation period that legally disabled her from filing.

Following the *Ramkumar Choudhary* precedent, the court held that the discretion to condone delay must be exercised judiciously and not as a "matter of generosity".

The court explicitly rejected the arguments of poverty, lack of education, or general ignorance of the law as valid justifications for overriding the statutory period of limitation.

It found the 117-day delay to be "grossly inordinate" and concluded that the applicant’s explanation did not constitute a plausible or sufficient cause in the eyes of the law.

Consequently, I.A. No. 01 of 2026 was rejected, and the criminal revision petition was dismissed as being barred by limitation and laches.