Madhya Pradesh High Court

Vague and hypothetical explanations fail to constitute sufficient cause for condoning inordinate delay in filing review petitions.

Ramcharan Adop v. Bihari and Others [2026:MPHC-IND:5772]

Madhya Pradesh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner filed a review petition seeking to challenge the judgment dated 12.03.2024 passed in a Second Appeal.

Source reference: para 3

However, the petition was filed with a delay of 589 days.

Source reference: no citation

The petitioner filed I.A. No. 11579 of 2025 under Section 5 of the Limitation Act to condone this delay.

Source reference: para 1

The petitioner, claiming to be a "rustic villager," argued that he was informed of the judgment late by his counsel and subsequently spent time filing a separate civil suit for declaration and injunction before seeking legal opinion to file the present review.

Source reference: paras 2-3

The respondents opposed the application, asserting the claim was barred by time.

Source reference: para 4
02

Issues

1. Whether the petitioner demonstrated "sufficient cause" under Section 5 of the Limitation Act to condone a delay of 589 days in filing the review petition.

Source reference: para 4
03

Law Applied

The court applied Section 5 of the Limitation Act, which requires the applicant to show "sufficient cause" for the delay.

Source reference: para 4

It relied on the principles from *Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy*, which established that while a pragmatic approach is needed, "sufficient cause" cannot be stretched to protect a "sleeping litigant" or gross negligence.

Source reference: para 6

It further cited *P.K. Ramachandran v. State of Kerala*, asserting that the law of limitation must be applied with rigor regardless of equitable grounds.

Source reference: para 7

*Pundlilk Jalam Patil v. Executive Engineer, Jalgaon*, which held that statutes of limitation are "statutes of peace" meant to prevent the disturbance of rights acquired through long enjoyment and to suppress fraud.

Source reference: para 8
04

Reasoning

The court found that the petitioner’s explanation was a "classic case" of a litigant waking up from a "deep slumber".

Source reference: para 4

It reasoned that the explanation provided in the "skeleton application" was hypothetical, vague, and lacked material particulars to constitute sufficient cause.

Source reference: paras 4, 11

The court emphasized that while a "liberal approach" is often cited, it cannot be used to jettison the substantive law of limitation, especially when a party has been thoroughly negligent.

Source reference: para 9

The court noted that the petitioner failed to provide a cogent or satisfactory reason for the 589-day gap, rendering the application "hopelessly time-barred".

Source reference: paras 4, 11
05

Holding

The court answered the issue in the negative, holding that the petitioner failed to demonstrate sufficient cause for the inordinate delay.

Consequently, I.A. No. 11579/2025 was dismissed.

Source reference: para 12

The Review Petition was dismissed as barred by limitation with no order as to costs.

Source reference: para 13
Madhya Pradesh High Court

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Ramcharan Adop v. Bihari and Others [2026:MPHC-IND:5772]

Madhya Pradesh High Court · no citation

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