Substantial delay cannot be condoned on vague medical grounds or used to re-argue merits in review.

The petitioner filed a Review Petition seeking to review a previous order.

Along with the petition, the petitioner filed I.A. No. 6588/2026 seeking condonation of a delay of 1389 days in filing the review.

The petitioner attributed the delay to medical injuries sustained in an accident on 18.11.2021, which allegedly rendered him unable to travel to Jabalpur to file the petition.

The petitioner provided certain medical documents but did not account for the entirety of the delay period.

1. Whether the petitioner established "sufficient cause" to condone a delay of 1389 days under the Limitation Act.

2. Whether the petitioner made out a case for review based on an error apparent on the face of the record.

The Court applied the standard of "sufficient cause" for condonation of delay, noting that delay cannot be condoned in a routine manner and the entire period must be satisfactorily explained.

Regarding review jurisdiction, the Court held it is limited to errors apparent on the face of the record or discovery of new evidence, and cannot be used for re-arguing merits.

The doctrine that "delay defeats equity" as established in Pundlik Jalam Patil v. Executive Engineer, Jalgaon Medium Project (2008).

Shivamma (dead) v. Karnataka Housing Board (2025), which cautioned Courts against condoning delays based on "frivolous and superficial grounds" or "administrative lethargy".

The Court found the petitioner’s explanation for the 1389-day delay to be vague and insufficient, as it failed to explain why steps could not have been taken through counsel or an authorized representative during the period of medical treatment.

Applying the principles from Pundlik Jalam Patil, the Court noted that the law assists the vigilant, not those who slumber over their rights.

On the merits of the review, the Court observed that the petitioner failed to point out any specific error in the original order; instead, the grounds raised amounted to a re-argument of the case, which exceeds the narrow scope of review jurisdiction.

The Court determined that the petition lacked both a procedural basis for condonation and a substantive basis for review.

The High Court rejected I.A. No. 6588/2026 and dismissed Review Petition No. 611 of 2026 on the grounds of both limitation and merits.

No order was made as to costs.