State cannot obtain condonation of delay through vague, unexplained administrative-delay applications.

The State of Madhya Pradesh and others filed an intra-court writ appeal under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyaypeeth Ko Appeal) Adhiniyam, 2005, challenging the order dated 28 January 2026 passed by the learned Single Judge in W.P. No. 4552 of 2023.

The appellants also filed I.A. No. 9822 of 2026 under Section 5 of the Limitation Act, 1963, seeking condonation of delay in filing the appeal.

The High Court noted that the Supreme Court, in State of M.P. v. Ramkumar Choudhary, SLP (C) Diary No. 48636 of 2024, decided on 29 November 2024, had directed States to streamline legal processes, fix responsibility for delays, and penalise responsible officers where appropriate.

The State Government had issued corresponding guidelines on 4 April 2026; however, the condonation application filed on 10 July 2026 continued to follow the old format.

The application merely alleged a “minor administrative delay,” left the number of delayed days blank, and assigned no specific reason for the delay.

1. Whether the State appellants had shown sufficient cause under Section 5 of the Limitation Act, 1963 for condonation of the delay in filing the writ appeal.

2. Whether the writ appeal could be entertained when the application for condonation of delay failed to disclose the length and reasons for the delay and did not comply with the applicable Supreme Court and State guidelines.

The Court applied Section 5 of the Limitation Act, 1963, under which delay may be condoned only upon the applicant demonstrating sufficient cause.

It also exercised jurisdiction over the intra-court appeal under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyaypeeth Ko Appeal) Adhiniyam, 2005.

The Court relied on the Supreme Court’s directions in State of M.P. v. Ramkumar Choudhary, requiring State authorities to streamline the machinery for legal opinion and institution of proceedings, fix responsibility for delay and lapses, and penalise responsible officers where governmental loss results.

The Court further considered the State Government’s guidelines dated 4 April 2026, issued pursuant to the Supreme Court’s directions.

The Court found that the condonation application did not establish sufficient cause.

It did not specify the actual period of delay, as the relevant number of days was left blank, and it offered only the vague assertion that certified copies had undergone routine departmental processing, resulting in an “unintentional and bona fide” administrative delay.

The application contained no factual explanation identifying the stages of delay, the officials responsible, or the steps taken to prosecute the appeal diligently.

This was contrary to the Supreme Court’s directions in Ramkumar Choudhary and the State’s guidelines dated 4 April 2026, particularly because the State continued to use the disapproved old format.

The Court therefore held that neither the Officers-in-Charge nor the Government Advocate had complied with the applicable requirements and that no reason whatsoever had been assigned for the delay.

Consequently, the writ appeal was dismissed as barred by limitation.