Poverty and financial constraints do not constitute sufficient cause for condonation of inordinate delay.

The appellant challenged an order dated 09.06.2025 passed in WPS No. 6056 of 2021, wherein a learned Single Judge partly allowed the appellant's writ petition by ordering reinstatement but denying back wages

Pursuant to that order, the appellant joined duty on 31.07.2025

The appellant subsequently filed Review Petition No. 414/2025 seeking back wages, which was dismissed on 15.12.2025

The present writ appeal was filed with a delay of 213 days from the original order

The appellant moved I.A. No. 01/2026 under Section 5 of the Limitation Act, citing financial hardship, poverty, and non-payment of salary post-reinstatement as reasons for the delay

1. Whether the appellant established "sufficient cause" for the condonation of a 213-day delay in filing the writ appeal under Section 5 of the Limitation Act

2. Whether financial constraints, poverty, or ignorance of law constitute adequate grounds to exercise judicial discretion in condoning inordinate delay

The Court primarily applied Section 5 of the Limitation Act, 1963, which requires the applicant to demonstrate "sufficient cause" for failing to approach the court within the prescribed limitation period

It relied on the Supreme Court’s decision in State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932), which held that "sufficient cause" must be an adequate reason that prevented the party from approaching the court and cannot be liberally interpreted in cases of negligence or inaction

The Court further cited Ajit Singh Thakur Singh v. State of Gujarat, affirming that sufficient cause must be traced to circumstances arising within the limitation period, and events occurring after the expiry of limitation cannot constitute such cause

The Court found the 213-day delay to be "grossly inordinate"

It observed that while the appellant was reinstated on 31.07.2025, he failed to pursue legal remedies immediately

The Court noted that the review petition appeared to have been filed at a belated stage merely to extend the limitation for the writ appeal

Applying the principles from Ramkumar Choudhary, the Court reasoned that the discretion to condone delay must be exercised with caution and that poverty, financial constraints, or ignorance of law do not, in the eyes of the law, fulfill the requirement of "sufficient cause"

The Court emphasized that the law of limitation creates valuable rights for the opposite party which cannot be lightly set aside due to a litigant's own inaction or lack of diligence

Consequently, the application for condonation of delay (I.A. No. 01/2026) was rejected, and the writ appeal was dismissed