Vague and unsupported explanations fail to establish sufficient cause for condoning delay in filing appeals.

The appellant-claimant filed a Miscellaneous Appeal under Section 173(1) of the Motor Vehicles Act, 1988, challenging the award dated 13.08.2018 passed by the Motor Accident Claims Tribunal, Datia, seeking an enhancement of the compensation amount.

Accompanying the appeal was I.A. No. 2626 of 2019, an application under Section 5 of the Limitation Act, seeking to condone a delay of 133 days in filing the appeal.

The appellant contended that the delay was unintentional and occurred because he lacked knowledge of the award until receiving information from a "notary source," after which he promptly contacted his counsel to file the appeal.

The respondent-Insurance Company opposed the application, arguing that the appellant failed to provide a satisfactory explanation for the delay and that the reasons assigned were vague and lacked material particulars.

Whether the appellant established "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of a 133-day delay in filing the appeal.

The court applied Section 5 of the Limitation Act regarding the condonation of delay and Section 173(1) of the Motor Vehicles Act, 1988.

The court relied on the principle that while social welfare legislations merit a liberal approach, "sufficient cause" cannot be expanded to render the Law of Limitation redundant.

The court cited Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy (2013), which held that a liberal approach should not enable a party to take the law for granted and that a lack of bona fides is a significant factor.

It further relied on Postmaster General v. Living Media India Ltd. (2012), establishing that in the absence of a plausible and acceptable explanation, delay cannot be condoned mechanically.

The court reasoned that a delay of 133 days is significant and requires a cogent explanation.

It found the appellant’s primary justification—lack of knowledge of the award—to be vague and unsupported by documentary evidence or specific dates.

Since the appellant was duly represented by counsel before the Claims Tribunal, the court determined he could not plead complete ignorance of the proceedings.

Applying the precedents of the Hon’ble Supreme Court, the court observed that the appellant failed to disclose the specific circumstances that prevented a timely filing.

Consequently, the court held that the explanation provided did not constitute "sufficient cause" as the appellant had not acted with the requisite diligence.

As the application for condonation of delay was rejected, the court held the Miscellaneous Appeal to be barred by limitation and dismissed it accordingly.