Procedural sanction delays do not constitute sufficient cause for condoning appellate delay.

The State of Chhattisgarh preferred a writ appeal against the order dated 15.04.2026 passed by the learned Single Judge in WPS No. 4741 of 2021, whereby the respondent’s termination order dated 21.09.2020 and the departmental appellate order dated 17.03.2021 were quashed.

The parties informed the Division Bench that an identical writ appeal, WA No. 775 of 2026, had already been dismissed on 18.08.2026, where the State’s application for condonation of a 70-day delay was rejected and the matter was also examined on merits. The present appeal was likewise stated to suffer from a delay of 73 days and to involve identical facts and issues.

The Division Bench accordingly dismissed the appeal in terms of its earlier order in WA No. 775 of 2026.

Whether the delay of 73 days in filing the writ appeal could be condoned in the absence of a satisfactory demonstration of “sufficient cause”?

Whether the learned Single Judge erred in quashing the respondent’s termination and departmental appellate orders on the ground of violation of natural justice and failure to conduct a proper departmental enquiry?

The Court applied the principle that delay under limitation law may be condoned only upon a clear, adequate and bona fide showing of “sufficient cause”; negligence, inaction, lack of diligence or procedural delay attributable to governmental authorities does not ordinarily justify condonation.

It relied on State of Madhya Pradesh v. Ramkumar Choudhary, 2024 INSC 932, Majji Sannemma v. Reddy Sridevi, 2021 SCC OnLine SC 1260, Ajay Dabra v. Pyare Ram, 2023 SCC OnLine SC 92, Basawaraj v. Special Land Acquisition Officer, (2013) 14 SCC 81, and Union of India v. Jahangir Byramji Jeejeebhoy, 2024 INSC 262.

The Court further applied the settled principles of natural justice and service law that a regular employee cannot be terminated summarily without definite charges, a proper departmental enquiry and an effective opportunity of hearing; procedural defects in appointment or regularization, absent fraud or misrepresentation by the employee, cannot by themselves justify such termination.

The Division Bench found the present appeal factually and legally identical to WA No. 775 of 2026 and adopted the reasoning in that decision.

Applying the limitation principles, the Court held that the State had not demonstrated any sufficient cause arising within the prescribed limitation period that prevented timely filing; mere procedural sanction or movement of the matter through State authorities was insufficient, particularly in view of the State’s lack of diligence.

On merits, the Court accepted that the respondent had been regularized and had continued in service for several years, while the termination was imposed without a regular departmental enquiry, definite charges or an effective hearing.

The non-speaking departmental appellate order also disclosed no proper application of mind.

Consequently, the learned Single Judge’s order did not warrant interference in intra-Court appellate jurisdiction.

Following its order in WA No. 775 of 2026, the Court dismissed WA No. 782 of 2026 as barred by delay and laches and on merits.

The quashing of the termination order dated 21.09.2020 and the departmental appellate order dated 17.03.2021 therefore remained undisturbed.