Inordinate delay cannot be condoned where the litigant demonstrates a persistent lack of due diligence and negligence.

The applicant sought the restoration of MCC No. 3028/2019, which had been dismissed on January 31, 2020, for non-compliance with a common conditional order.

This earlier MCC (3028/2019) had itself been filed to restore Second Appeal No. 1214/2019, which was dismissed on September 25, 2019, due to the applicant's failure to cure defaults.

The applicant filed the current restoration application along with I.A. No. 7154/2025, seeking to condone a delay of 855 days.

The applicant cited the COVID-19 pandemic and the death of his wife on May 3, 2020, as reasons for the delay.

1. Whether the applicant established "sufficient cause" under Section 5 of the Limitation Act to condone the inordinate delay of 855 days in filing the restoration application.

2. Whether circumstances arising after the expiration of the limitation period can be considered as sufficient cause for the initial failure to file within time.

The Court primarily applied Section 5 of the Limitation Act regarding the condonation of delay.

It relied heavily on the precedent set by the Hon'ble Supreme Court in State of Madhya Pradesh v. Ramkumar Choudhary (2024), which mandates that delay should not be excused as a matter of generosity and that the applicant must prove reasonable diligence.

Furthermore, the court applied the principle from Ajit Singh Thakur Singh v. State of Gujarat (1981), establishing that "sufficient cause" must be traced to events occurring within the prescribed limitation period, not subsequent to its expiry.

The Court observed a consistent pattern of negligence and lack of diligence by the applicant.

It noted that the Second Appeal was dismissed in 2019 and the subsequent restoration MCC was dismissed in January 2020—well before the March 2020 COVID-19 lockdown.

The Court adopted the Supreme Court's reasoning that the "Sword of Damocles" cannot hang over a respondent indefinitely due to a litigant's whims.

Applying the rule that sufficient cause must exist during the actual limitation period, the Court found the applicant's justifications (the pandemic and personal loss) insufficient because the defaults and initial dismissals occurred prior to those events.

The Court concluded that no satisfactory material was placed on record to show the applicant was prevented by circumstances beyond his control; rather, the record indicated a chronic failure to comply with court orders.

The Court dismissed I.A. No. 7154/2025 (condonation of delay) and consequently dismissed MCC No. 1471/2022 as being barred by limitation.