Vague and unsubstantiated claims of illness or poverty do not constitute sufficient cause for condoning inordinate delay.

The appellants filed a Miscellaneous Appeal under Section 173(1) of the Motor Vehicles Act, 1988, seeking an enhancement of the compensation awarded by the Additional Member, Motor Accident Claims Tribunal (MACT), Seondha, Datia, in an order dated 09.12.2016

Along with the appeal, the appellants moved I.A. No. 3487 of 2021 under Section 5 of the Limitation Act to condone a delay of 413 days in filing

The appellants contended the delay arose because they were poor, uneducated, and unaware of procedural requirements; they further alleged that one appellant suffered from mental illness during the period, preventing timely legal action

The respondent-Insurance Company opposed the application, asserting that the delay was inordinate and the explanation was vague and lacked supporting medical documentation

1. Whether the appellants demonstrated "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of a 413-day delay in filing the appeal

The court primarily applied Section 5 of the Limitation Act, 1963, which requires the applicant to show "sufficient cause" for delay

while the Motor Vehicles Act is social welfare legislation necessitating a liberal approach, such an approach cannot render the Law of Limitation redundant

Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy (2013) 12 SCC 649, which held that the concept of a liberal approach should not enable a party to take the law for granted

Postmaster General v. Living Media India Ltd. (2012) 3 SCC 563, which established that in the absence of a plausible and acceptable explanation, delay cannot be condoned mechanically

The Court found that a delay of 413 days is significant and cannot be treated as trivial

It observed that the appellants' explanation was comprised of general and vague assertions regarding poverty and ignorance of the law without disclosing specific facts or evidence to account for the entire period of delay

Specifically, the court noted that the plea of mental illness was entirely unsupported by medical records or cogent evidence

the appellants were represented by counsel before the Claims Tribunal and thus could not plead complete ignorance of the impugned award

The court reasoned that since a valuable right had accrued to the respondent due to the expiration of limitation, and the appellants failed to show due diligence or a bona fide explanation, "sufficient cause" was not established

the Court dismissed I.A. No. 3487 of 2021 (the application for condonation of delay)

the Miscellaneous Appeal was dismissed as barred by limitation