Personal hardship and document collection difficulties do not constitute sufficient cause for condoning inordinate delay.

The applicants filed a criminal revision petition against an order dated January 3, 2024, passed by the Family Court, Dhamtari, which rejected applicant No. 1's (wife's) maintenance claim on the ground of living separately without sufficient cause, while awarding ₹3000/- per month in maintenance to applicant No. 2 (minor child) from the date of the order.

There was a delay of 686 days in filing the revision petition.

The applicants attributed this delay to applicant No. 1 residing with her children at her parental home and facing considerable hardship in day-to-day life, which prevented her from collecting necessary documents and approaching counsel within the limitation period.

Whether the delay of 686 days in preferring the criminal revision petition deserves to be condoned.

The court primarily applied the legal principles governing the condonation of delay under the Limitation Act, emphasizing that "sufficient cause" must be demonstrated.

It relied on the Supreme Court's decisions in State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932), which affirmed that the discretion to condone delay must be exercised judiciously and that "sufficient cause" cannot be liberally interpreted if negligence, inaction, or lack of bona fides is attributed to the party.

The court also cited Majji Sannemma v. Reddy Sridevi (2021 SCC Online SC 1260) and Basawaraj v. Special Land Acquisition Officer (2013 14 SCC 81) through Ajay Dabra v. Pyare Ram (2023 SCC Online 92), holding that where a case is presented beyond limitation, the applicant must explain the "sufficient cause" that prevented timely action, and negligence or lack of bona fides does not justify condonation.

Furthermore, the court referred to Union of India v. Jahangir Byramji Jeejeebhoy (D) through his legal heir (2024 INSC 262), which stated that delay should not be excused as a matter of generosity and the length of delay is a relevant factor.

The court also highlighted that "sufficient cause" must be a circumstance arising before the limitation period expired, as per Ajit Singh Thakur Singh and Another v. State of Gujarat (AIR 1981 SC 733).

The court meticulously applied the established legal principles regarding condonation of delay, particularly distinguishing between sympathy and "sufficient cause."

It noted that the applicants’ explanation of facing hardships while residing with her children at her parental house, though invoking sympathy, did not constitute "sufficient cause" in the eyes of the law, as ignorance of law or hardship alone are not adequate justifications.

The court observed that the applicants failed to point out any circumstance arising within the period of limitation that disabled them from approaching the court, indicating prolonged inaction.

The court underscored that a valuable right accrues to the opposite party once the limitation period expires, and this right cannot be lightly taken away without a clear and satisfactory demonstration of diligence and bona fides.

Given the inordinate delay of 686 days and the lack of a legally acceptable "sufficient cause," the court found that condoning the delay would be contrary to the principles of sound public policy and the finality in litigation that the doctrine of limitation seeks to ensure.

The application for condonation of delay was rejected because the 686-day delay was grossly inordinate and the explanation provided, while appearing bona fide, did not legally constitute "sufficient cause."

As a consequence, the criminal revision petition was dismissed as being hopelessly barred by limitation.