Vague Administrative Reasons and Undisclosed Property Sale Do Not Constitute Sufficient Cause for Condoning Delay

The petitioner company sought to quash an ex-parte award dated December 7, 2022, from the Labour Court, Ahmedabad, which directed the reinstatement of the respondent workman with 50% back wages

Additionally, the petitioner challenged a subsequent order dated October 9, 2024, which rejected their application to condone a six-month delay in filing for the restoration of the case

The petitioner argued that the delay was due to administrative issues and a change in office address

However, records indicated the petitioner had appeared through counsel earlier in the proceedings but failed to file a reply or contest the matter further

1. Whether the petitioner established "sufficient cause" under the Limitation Act to warrant the condonation of delay in filing the restoration application

2. Whether the Labour Court’s refusal to set aside the ex-parte order was legally sound given the petitioner's conduct during the proceedings

The court applied the principles of the Limitation Act regarding the condonation of delay, emphasizing that "sufficient cause" requires a reasonable and palatable explanation rather than vague administrative reasons

The court relied on the doctrine that a litigant who is inactive or suppresses material facts—such as the knowledge of recovery proceedings—is not entitled to discretionary leniency

It further held that the burden of proving a valid excuse for non-appearance lies strictly with the erring party, and the mere negligence of an advocate does not automatically constitute a sufficient ground

The High Court found the petitioner’s explanations to be contradictory and an "eyewash". While the petitioner claimed they did not receive notice due to a change of address in 2016, the Court noted that they used the same "old" address in their current delay application, undermining their credibility

The petitioner appeared through counsel in 2016 but abandoned the case, indicating a lack of diligence

The Court highlighted that the petitioner suppressed the fact that they were already participating in related recovery proceedings, proving they had knowledge of the award earlier than claimed

Consequently, the Court determined that the petitioner’s conduct was not bona fide and the "administrative reasons" cited were insufficient to bypass the prescribed 30-day limitation period

The interim relief was vacated, and the Court ordered the disbursement of a previously deposited amount of ₹10,000 to the respondent workman