State authorities’ procedural delays do not constitute sufficient cause for condoning appellate delay.

Sunil Yadu, working as a Peon with the Chhattisgarh Council of Science and Technology, challenged the termination order dated 21.09.2020 and the rejection of his departmental appeal dated 17.03.2021.

The learned Single Judge allowed WPS No. 4897 of 2021 on 15.04.2026, quashed both orders, and granted relief including reinstatement with notional pay and seniority, while denying back wages.

The State preferred the present intra-court appeal with a delay of 72 days.

The parties informed the Division Bench that the issue was identical to WA No. 775 of 2026, which had been dismissed on 18.08.2026 for delay and on merits.

Whether the delay of 72 days in filing the writ appeal could be condoned upon the explanation that the delay resulted from obtaining procedural sanction from the State authorities?

Whether the learned Single Judge erred in quashing the 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 may be condoned only upon a clear and satisfactory showing of “sufficient cause”; negligence, inaction, lack of bona fides, or administrative lethargy do not justify condonation.

Relying 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, and Basawaraj v. Special Land Acquisition Officer, (2013) 14 SCC 81, the Court reiterated that limitation must ordinarily be applied strictly and that sufficient cause must relate to circumstances preventing filing within the prescribed limitation period.

It further relied on Union of India v. Jahangir Byramji Jeejeebhoy (D), 2024 INSC 262, holding that delay cannot be excused as an act of generosity and that substantial justice cannot be rendered by causing prejudice to the opposite party.

On merits, the Court applied the principles of natural justice and fair procedure, holding that a regular employee could not be terminated without definite charges, an effective opportunity of hearing, and a proper departmental enquiry.

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

The State’s explanation that time was consumed in obtaining procedural sanction did not establish any circumstance arising within the limitation period that prevented timely filing; it instead demonstrated administrative inaction, which did not constitute sufficient cause.

The Court also accepted the merits reasoning of the learned Single Judge: the respondent had been regularized and had continued in service for several years, but was terminated without a regular enquiry, definite charges, or an effective hearing.

The termination orders were therefore contrary to natural justice, while the departmental appellate order was non-speaking and reflected no proper application of mind.

It declined to condone the 72-day delay and dismissed the writ appeal as barred by delay and laches.

Independently, it found no error in the learned Single Judge’s order quashing the termination dated 21.09.2020 and the departmental appellate order dated 17.03.2021, particularly because the termination was effected without a proper departmental enquiry or compliance with natural justice.

The appeal was accordingly dismissed in terms of the order dated 18.08.2026 in WA No. 775 of 2026, with no separate order as to costs.