Section 482 petitions must be filed within reasonable time despite absence of statutory limitation period.

The petitioner filed a petition under Section 482 of the Code of Criminal Procedure (Cr.P.C.) seeking to set aside an order dated January 19, 2023, passed by the Additional Sessions Judge, Rohini Courts, which discharged an accused and quashed a summoning order

Accompanying the petition was an application for condonation of delay of 412 days (though the petitioner argued the actual delay was between 316 and 346 days)

The petitioner, a practicing advocate appearing in person, contended that the delay was not intentional but occurred because he needed significant time to conduct legal research to understand the implications of the impugned order

He further argued that Section 482 Cr.P.C. does not prescribe a specific limitation period

The State and private respondents opposed the application, citing a lack of due diligence and an insufficient explanation for the inordinate delay

1. Whether the delay in filing the petition under Section 482 Cr.P.C. deserves to be condoned based on the explanation of "legal research" and "difficulty in understanding" the order by a practicing advocate.

2. Whether a petition under Section 482 Cr.P.C. can be entertained after an inordinate delay in the absence of a prescribed statutory limitation period.

The court primarily applied the principle of "sufficient cause" for condonation of delay, noting that while the length of delay is less critical than the cause, the cause must be substantial and not a mere excuse

where no statutory time limit is prescribed, a remedy must still be sought within a "reasonable time"

90 days (at par with a revision petition) is generally considered a reasonable period for invoking Section 482 Cr.P.C. jurisdiction

condonation is a matter of judicial discretion, not a right

The court found the petitioner's explanation for the delay—the need for extensive legal research to understand the order—to be unsatisfactory and insufficient

It specifically noted that such a justification carries even less weight when the litigant is a practicing advocate, as legal research and consultation are routine professional exercises

The court reasoned that if "difficulty in understanding a judicial order" were accepted as sufficient cause for a year-long delay, the law of limitation and the principles of delay and laches would become "otiose"

Although Section 482 Cr.P.C. has no prescribed limitation, the court emphasized that it must be filed within a reasonable window, typically 90 days, unless a cogent day-to-day explanation for the delay is provided

The petitioner failed to disclose specific dates or circumstances that prevented him from approaching the court sooner, reflecting a lack of due diligence

Consequently, the main petition under Section 482 Cr.P.C. was dismissed as being barred by delay and laches

The court held that even in the absence of a specific limitation period, the inherent powers of the High Court cannot be invoked at the "sweet will" of a litigant after an unreasonable lapse of time