Madhya Pradesh High Court
Civil Procedure and EvidenceCivil Law

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
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 Court. LawLens
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
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Limitation Act, 19631

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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