Repeated representations and proceedings in an incorrect forum do not constitute sufficient cause for condoning delay.

The applicant’s father died on 23 June 2021. The applicant applied for compassionate appointment on 27 January 2022, submitted the prescribed application on 9 February 2022, and furnished supporting documents on 26 April 2022. He thereafter sent several letters and emails and made telephone calls seeking action on his request.

The Compassionate Appointment Committee rejected his claim, and the rejection was communicated by letter dated 13 September 2023. The applicant subsequently approached the National Commission for Scheduled Castes and later filed Writ Petition No. 509/2025 before the Karnataka High Court on 6 January 2025.

On 7 April 2025, the High Court dismissed the writ petition on the ground that the Central Administrative Tribunal had jurisdiction, while granting liberty to approach the Tribunal and directing that the time spent in the writ proceedings be deducted for limitation purposes.

The applicant filed the present Original Application on 22 April 2025 and sought condonation of delay through M.A. No. 210/2025, filed on 2 June 2025.

Whether the delay in filing the Original Application challenging the rejection of compassionate appointment was liable to be condoned under Section 21 of the Administrative Tribunals Act, 1985, read with Section 14 of the Limitation Act, 1963.

Whether the applicant’s repeated representations, correspondence with the respondents, intervention by the National Commission for Scheduled Castes, and prosecution of the writ petition before the High Court constituted sufficient cause for condoning the delay.

Whether the Original Application was barred by limitation and consequently liable to be dismissed.

Section 21(1)(a) of the Administrative Tribunals Act, 1985 requires an application challenging a final order to be filed within one year from the date of that order.

Section 14(2) of the Limitation Act, 1963 permits exclusion of time spent prosecuting, with due diligence and in good faith, proceedings before a court unable to entertain the matter for want of jurisdiction or a similar cause.

The Tribunal relied on Union of India & Anr. v. Jahangir Byramji Jeejeebhoy for the principles that limitation is founded on public policy, that sufficient cause must be bona fide and established by the applicant, and that merits should not ordinarily influence the condonation decision unless the explanation and opposition are evenly balanced.

It also applied the principles in Lanka Venkateswarlu v. State of Andhra Pradesh, Pundlik Jalam Patil v. Executive Engineer, and Ramlal v. Rewa Coalfields Ltd., that liberal construction of “sufficient cause” does not dispense with the requirement of a genuine explanation, and that a litigant must demonstrate diligence.

The Tribunal further relied on the doctrine that law assists the vigilant and not those who sleep over their rights, as reflected in Chennai Metropolitan Water Supply and Sewerage Board v. T.T. Murali Babu and Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy.

The Tribunal held that the limitation period commenced from the rejection of the compassionate appointment claim on 13 September 2023, rather than from the dates of the applicant’s subsequent representations or correspondence.

Consequently, the applicant ought to have approached the Tribunal by approximately September 2024 under Section 21 of the Administrative Tribunals Act. Even after granting the benefit of excluding the three months spent pursuing the writ petition before the High Court from 6 January to 7 April 2025 under Section 14 of the Limitation Act, the application remained substantially delayed.

The applicant’s letters, emails, telephone calls, and approach to the National Commission did not suspend or extend the statutory limitation period.

The Tribunal also found that the applicant, being a postgraduate, should have approached the Tribunal directly and that his mistaken recourse to the High Court did not demonstrate sufficient diligence. The High Court’s order merely excluded the time spent in the writ proceedings and did not excuse the earlier period of inaction.

Applying the principles that limitation cannot be defeated by stale claims and that sufficient cause must explain the entire period of delay, the Tribunal found no valid or justifiable ground for condonation.

The applicant failed to establish sufficient cause for condonation, and M.A. No. 210/2025 was dismissed.

Consequently, O.A. No. 257/2025 was dismissed as time-barred. The parties were directed to bear their own costs.