Unexplained inordinate delay cannot be condoned merely because similarly situated claimants received relief.

The applicant, a claimant in LAQ Case No. 38 of 2004 concerning acquisition of land in village Lakhvad, sought condonation under Section 5 of the Limitation Act, 1963, of a delay of 6,472 days in filing a First Appeal against the Reference Court’s award dated 6 May 2008.

The applicant contended that the acquisition proceedings for the village had been divided into five groups, and that appeals arising from other connected LAQ cases had previously been admitted after condoning delay.

The applicant further pleaded that he was an illiterate and poor agriculturist, had learned about the possibility of enhancement only in 2025, and had subsequently obtained legal advice.

He also relied on the alleged non-payment of solatium-related amounts and the 12% additional compensation, which were stated to have been deposited in March 2025.

The applicant additionally referred to pending proceedings before the Supreme Court and precedents in which substantial delays had been condoned.

The State opposed the application on the ground that the delay was inordinate and unexplained.

1. Whether the applicant had shown “sufficient cause” under Section 5 of the Limitation Act, 1963, for condoning the delay of 6,472 days in filing the First Appeal?

2. Whether the condonation of delay in appeals arising from connected land-acquisition proceedings, or the pendency of similar proceedings, entitled the applicant to parity or justified condonation in the present case?

3. Whether the applicant’s poverty, illiteracy, lack of legal advice, and the subsequent deposit of compensation-related amounts constituted sufficient cause for the delay?

The Court applied Section 5 of the Limitation Act, 1963, under which an appeal may be admitted after limitation only when the applicant satisfies the Court that sufficient cause prevented timely filing.

It held that limitation law is founded on public policy and finality, while Section 5 is to be construed liberally only where the delay is supported by a credible explanation and due diligence; liberal or justice-oriented language cannot override the substantive law of limitation.

Relying on Pathapati Subba Reddy v. Special Deputy Collector (LA), (2024) 12 SCC 336, the Court reiterated that condonation is discretionary, that inordinate delay, negligence and want of due diligence may justify refusal, and that relief granted to similarly situated persons does not automatically entitle another claimant to condonation.

The Court also relied on State of Odisha v. Managing Committee of Namatara Girls High Schools, 2026 INSC 148, for the distinction between a legally acceptable explanation and a mere excuse.

The Court also relied on Government of Karnataka v. Gowramma, (2007) 13 SCC 482, for the principle that cases must be decided on their own facts and cannot be disposed of by mechanically applying precedents.

The Court found that the applicant had not explained the individual periods comprising the nearly twenty-year delay.

The assertions that the applicant learned of other claimants’ appeals only in 2025, lacked legal knowledge, was poor and illiterate, needed time to arrange court fees, or later discovered alleged deficiencies in compensation were general and unsupported by documentary evidence.

None of these circumstances, in the Court’s view, prevented the applicant from filing the appeal within the prescribed period.

The fact that connected appeals had been admitted after condonation did not establish a right to identical treatment, since condonation depends on the facts and explanation in each case.

Similarly, the deposit of certain compensation-related amounts in March 2025 and the pendency of proceedings before the Supreme Court did not explain the applicant’s failure to challenge the 2008 decision earlier.

In the absence of cogent evidence of sufficient cause or due diligence, the Court declined to exercise its discretionary power under Section 5.

The application for condonation of delay was therefore dismissed, the Rule was discharged, and the prayer for registration of the First Appeal was rejected.

Any consequential civil applications were disposed of as not surviving.