Facts
The applicant filed a criminal revision challenging an order dated 04.11.2023
Source reference: para 2The revision was filed with a delay of 777 days
Source reference: para 1The applicant sought condonation of this delay via I.A. No. 01 of 2026, citing severe renal irregularities since 2023, hospitalization until 26.11.2025, and subsequent medical advice for bed rest until 31.03.2026
Source reference: para 2He further stated that the certified copy of the impugned order was applied for only on 25.08.2025 and received on 11.09.2025
Source reference: para 2Issues
1. Whether the delay of approximately 777 days in preferring the criminal revision petition deserves to be condoned under the "sufficient cause" standard.
Source reference: para 4Law Applied
The court applied the principle that condonation of delay requires a demonstration of "sufficient cause," meaning adequate reasons that prevented the litigant from approaching the court within the limitation period
Source reference: para 5It relied on State of Madhya Pradesh v. Ramkumar Choudhary (2024), which held that limitation must be applied with rigour and that discretion should not be exercised as a matter of generosity
Source reference: para 5The court further cited Basawaraj v. Special Land Acquisition Officer (2013) to establish that negligence, inaction, or lack of bona fides precludes condonation
Source reference: para 5Crucially, it applied the doctrine from Ajit Singh Thakur Singh v. State of Gujarat (1981), which stipulates that "sufficient cause" must be traced to events arising within the period of limitation, rather than circumstances occurring after the limitation has already expired
Source reference: para 5.1 (7)Reasoning
The Court found the 777-day delay to be "grossly inordinate"
Source reference: para 7In applying the Rule of Law, the Court determined that the applicant's medical explanation—renal irregularities and prolonged recovery—did not legally constitute "sufficient cause" for such a substantial period
Source reference: para 7The Court reasoned that the applicant failed to identify specific circumstances arising within the original limitation period that effectively disabled him from filing the revision
Source reference: para 8It emphasized that the law of limitation is a matter of public policy intended to ensure finality in litigation; thus, the rights accrued to the respondents by the expiry of the limitation period cannot be lightly set aside
Source reference: para 8The Court concluded that the applicant exhibited a lack of diligence and failed to provide a satisfactory explanation for the prolonged inactivity
Source reference: para 8Holding
The High Court held that no case for condonation of delay was established as the explanation provided was inadequate under the law
Consequently, the Court rejected the application for condonation of delay (I.A. No. 01 of 2026) and dismissed the criminal revision petition as barred by limitation and laches
Source reference: para 9Original Court PDF
CHANDAN SINGHvsSMT. VISHESHTA SINGH
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in