"Sufficient cause" for condoning delay requires liberal construction to facilitate adjudication of matters on substantial merits.

The applicants, Police Constables inducted in 1990, challenged a promotional order dated 28.05.2015 that promoted respondents 4 to 41 to the post of Head Constable

They alleged that out of 101 promoted posts, 38 were excessively diverted to the reserved (SC) category, exceeding the prescribed 15% quota

In a previous proceeding (OA No. 224/2016), the Tribunal directed the respondents to grant a personal hearing and pass a speaking order

Consequently, the respondents issued a speaking order on 25.07.2016, asserting the promotions were lawful

The applicants filed the present OA on 17.12.2021, seeking to set aside the 2015 promotion and 2016 speaking order, resulting in a delay of 1234 days

The applicants attributed the delay to the non-supply of documents by the respondents, the pending resolution of reservation law in the Supreme Court (Jarnail Singh case), and the COVID-19 pandemic

1. Whether the applicants established "sufficient cause" to condone the delay of 1234 days in filing the Original Application

2. Whether the pending legal uncertainty regarding reservation in promotion and the respondents' recent finalization of the seniority list justify a liberal approach to limitation

Section 5 of the Indian Limitation Act, 1963, which empowers courts to condone delay upon a showing of "sufficient cause" to ensure matters are decided on merits rather than technicalities

Collector Land Acquisition, Anantnag & Ors. v. Mst. Katiji & Ors. (AIR 1987 SC 1353), which mandates a liberal, pragmatic, and non-pedantic approach to condonation of delay to subserve the ends of justice

The Tribunal observed that the cause of action arose following the speaking order of 25.07.2016, and the applicants failed to approach the Tribunal within a reasonable period thereafter

While the applicants claimed to have submitted representations between 2017 and 2019, they failed to produce copies of such documents

However, the Tribunal emphasized that the core issue—reservation in promotion—remains sub judice before the Supreme Court in Jarnail Singh & Ors. v. Lachhmi Narain Gupta & Ors.

Furthermore, the respondents issued a final seniority list on 11.01.2023, which explicitly stated it was subject to the outcome of the present litigation

The Tribunal reasoned that since substantial justice and technical considerations were in conflict, the former must prevail, especially as there was no evidence that the delay was deliberate or mala fide

It held that the expression "sufficient cause" must receive a liberal construction to advance substantial justice, particularly given the ongoing administrative actions regarding the seniority list

The respondents were directed to file their reply to the main OA by 06.03.2026