Inordinate Delay Cannot Be Condoned Without Sufficient Cause Arising Within the Statutory Limitation Period

The applicant, an employee of the Central Bank of India, challenged an ex-parte order dated 21.04.2025 passed by the Family Court, Manendragarh, which directed him to pay monthly maintenance of Rs. 10,000 to the non-applicant

The applicant filed the present criminal revision with a delay of 256 days.

He contended that he was never served notice by the Family Court and only gained knowledge of the order on 23.01.2026, when his employer received a memorandum directing salary deductions for maintenance

Consequently, he filed I.A. No. 03 of 2026 seeking condonation of the inordinate delay

1. Whether the delay of 256 days in preferring the revision petition deserves to be condoned under the standard of "sufficient cause"

the doctrine of "sufficient cause" for condonation of delay as interpreted by the Supreme Court in State of Madhya Pradesh v. Ramkumar Choudhary (2024), which mandates that limitation must be applied with rigor and "sufficient cause" cannot be liberally interpreted in cases of negligence or inaction

Ajay Dabra v. Pyare Ram (2023), establishing that a party who fails to act diligently cannot claim a justified ground for condonation

Ajit Singh Thakur Singh v. State of Gujarat (1981), which stipulates that the "sufficient cause" must be traced to circumstances arising within the original period of limitation, rather than events occurring after its expiry

The Court examined whether the applicant’s claim—that he was unaware of the ex-parte proceedings until the execution stage—constituted "sufficient cause"

Following the precedent in Ramkumar Choudhary, the Court noted that the discretion to condone delay must be exercised judiciously and not as a matter of generosity

The Court observed that the applicant remained inactive for a prolonged period and failed to demonstrate any circumstance arising within the statutory limitation period that prevented him from approaching the Court

The Court held that ignorance of the law or simple sympathy does not override the valuable rights accrued to the opposite party due to the lapse of time

The explanation was deemed inadequate as it failed the test of "bona fide reason" and demonstrated a lack of diligence

Consequently, the criminal revision petition was dismissed as being barred by limitation and laches

No relief was granted against the impugned maintenance order