Procedural delays in departmental sanctions for filing appeals do not constitute "sufficient cause" for condonation of delay.

The husband of the respondent, late Hafiz Qureshi, held a medical insurance policy (Sum Assured: Rs. 3,00,000) from the petitioner.

Following his death during treatment in December 2021, the respondent’s claim was ignored by the petitioner, leading her to file a complaint before the District Consumer Disputes Redressal Commission.

On 29.01.2025, the District Commission awarded Rs. 8,35,591 as compensation.

The petitioner challenged this before the State Consumer Commission with a delay of 86 days, attributing the lapse to procedural requirements for obtaining sanctions.

The State Commission rejected the condonation application and dismissed the appeal on 28.07.2025.

This order was subsequently affirmed by the National Consumer Disputes Redressal Commission (NCDRC) on 28.11.2025.

The petitioner then moved the High Court under Article 227 of the Constitution.

1. Whether the State and National Commissions committed a jurisdictional error or perversity by refusing to condone the 86-day delay in filing the appeal.

2. Whether the High Court, under its supervisory jurisdiction under Article 227, should interfere with concurrent findings regarding the sufficiency of cause in limitation matters.

Section 51(1) of the Consumer Protection Act, 2019, which mandates specific timelines for appeals and requires "sufficient cause" for condonation.

Supervisory jurisdiction under Article 227 is limited to correcting patent perversity, gross jurisdictional errors, or manifest illegality, and is not a substitute for an appellate forum.

Article 227 is a correctional jurisdiction reserved for grave dereliction of duty and not for correcting every error of fact or law, as held in Garment Craft v. Prakash Chand Goel (2022).

Supreme Court precedents on limitation, including State of MP v. Bherulal and Pathapati Subbareddy v. Special Deputy Collector, restrict liberal condonation for bureaucratic/procedural delays.

The Court observed that the petitioner’s counsel was present when the District Commission passed the order and obtained a certified copy shortly thereafter, yet waited until June 2025 to file the appeal.

The High Court noted that the "procedural delay" in obtaining departmental sanctions is not a sufficient or bona fide reason to bypass statutory limitation periods.

In evaluating the orders of the State and National Commissions, the Court found that both forums had assigned cogent reasons and relied on established Supreme Court jurisprudence to conclude that the petitioner failed to show "sufficient cause".

The court reasoned that since the forums below exercised their discretion based on settled legal principles, there was no "patent perversity" or "manifest injustice" that would warrant intervention under the restrictive scope of Article 227.

The Court dismissed the writ petition, affirming that the statutory mandate of limitation cannot be diluted merely to allow an adjudication on merits when the delay remains unsatisfactorily explained.