Unexplained inordinate delay cannot be condoned merely on liberal or parity-based considerations.

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

They contended that five acquisition groups had been created for the same public purpose and that appeals arising from other groups had been entertained after condoning delay.

They further relied on the State’s recent deposit of additional compensation, including solatium-related amounts, in March 2025; their alleged lack of legal knowledge; poverty and illiteracy; and their subsequent discovery of allegedly more favourable decisions concerning deductions in determining compensation.

The respondents opposed the application on the ground that the extensive delay had not been satisfactorily explained.

Whether the applicants had shown “sufficient cause” under Section 5 of the Limitation Act, 1963, to condone the delay of 6,472 days in filing the First Appeal?

Whether the fact that delay had been condoned in appeals arising from other acquisition groups, or that additional compensation had subsequently been deposited, entitled the applicants to similar condonation?

Whether the proposed appeal could be registered after condonation of 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 establishes sufficient cause for the delay.

Although Section 5 is to receive a liberal construction in furtherance of substantial justice, liberal or justice-oriented considerations cannot override the statutory policy of limitation, particularly where negligence, inaction, want of bona fides, or lack of due diligence is apparent.

Relying on Pathapati Subba Reddy v. Special Deputy Collector (LA), (2024) 12 SCC 336, the Court held that condonation is discretionary; inordinate delay, negligence, and want of due diligence may justify refusal even where some explanation is offered, and parity with other litigants does not by itself establish entitlement to condonation.

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

Government of Karnataka v. Gowramma, (2007) 13 SCC 482, for the principle that cases must be decided on their own facts and cannot be determined by blindly applying another decision.

The Court found that the applicants had not explained the delay continuously or specifically for nearly twenty years.

Their reliance on the condonation of delay in appeals arising from other LAQ groups did not constitute sufficient cause, because those orders were based on their own facts and could not automatically confer parity.

The subsequent deposit of additional compensation in March 2025, the applicants’ alleged lack of legal awareness, poverty, illiteracy, consultation with co-villagers, and later discovery of favourable authorities explained only their recent decision to litigate and did not account for the failure to file an appeal within limitation.

The Court therefore concluded that the pleaded reasons were general, vague, unsupported by documentary evidence, and insufficient to overcome the applicants’ prolonged inaction and lack of due diligence.

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

Any connected civil applications were also disposed of as not surviving.