Poverty and ignorance of law do not constitute sufficient cause for condoning inordinate delay.

The applicants (wife and minor daughter) sought to challenge a Family Court order dated 23.05.2023 through a criminal revision filed with a delay of 954 days

To explain the delay, the applicants filed I.A. No. 01/2026, citing the illness and sudden death of their trial court advocate, which left them unaware of the legal proceedings

They further cited the death of the first applicant’s father, subsequent financial stringency, and general lack of legal awareness

The applicants had also moved an application for enforcement of the maintenance order under Section 147 of the BNSS in December 2025, but the notice was returned unserved

1. Whether the delay of 954 days in preferring the criminal revision deserves to be condoned on the grounds of "sufficient cause."

The Court primarily applied the principle of "sufficient cause" under the law of limitation, emphasizing that the discretion to condone delay must be exercised judiciously based on the facts of each case

It relied on State of Madhya Pradesh v. Ramkumar Choudhary (2024 INSC 932) and Basawaraj v. Special Land Acquisition Officer (2013 14 SCC 81), which established that negligence, inaction, or lack of bona fides cannot be overlooked under the guise of substantial justice

The Court further applied the rule from Ajit Singh Thakur Singh v. State of Gujarat (AIR 1981 SC 733), asserting that "sufficient cause" must arise within the prescribed period of limitation to justify the failure to file on time

The Court determined that the delay of 954 days was "grossly inordinate"

It reasoned that while the applicants’ claims of poverty and financial crisis might evoke sympathy, they do not legally constitute "sufficient cause" for condoning such a long delay

The Court noted that the applicants remained inactive for a prolonged period and failed to demonstrate any specific circumstance that arose within the initial limitation period which prevented them from approaching the Court

Following the Supreme Court’s stance in Jahangir Byramji Jeejeebhoy (2024 INSC 262), the Court held that the rules of limitation are based on public policy and finality, and that rendering justice to one party should not cause undue prejudice to the opposite party who has gained a right through the expiry of the limitation period

The application for condonation of delay (I.A. No. 01/2026) was rejected

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