Vague assertions of lack of knowledge fail to constitute sufficient cause for condoning inordinate delay.

The appellant/claimant filed this miscellaneous appeal under Section 173(1) of the Motor Vehicles Act challenging the award dated 21.04.2008 passed by the Additional Motor Claims Tribunal, Guna, in Claim Case No. 80/2007, which awarded compensation of Rs. 54,040/-.

Along with the appeal, the appellant filed I.A. No. 7431/2010 under Section 5 of the Limitation Act seeking condonation of a 662-day delay.

The appellant argued that he lacked knowledge of the award because he resided in Village Aron while the proceedings were in Guna, and that court summons had been served on his son during his absence.

He claimed to have learned of the decision on 17.04.2010 after returning to the station and contacting his counsel.

1. Whether the appellant established "sufficient cause" under Section 5 of the Limitation Act to warrant the condonation of a 662-day delay in filing the appeal.

The court primarily applied Section 5 of the Limitation Act, which mandates that an applicant must show "sufficient cause" for failing to prefer an appeal within the prescribed period.

The court relied on the precedent in Basawaraj and another v. Special Land Acquisition Officer (2013) 14 SCC 81, which posits that limitation law is founded on public policy and delay cannot be condoned in a routine manner without sufficient cause.

Furthermore, it applied the principle from Postmaster General and others v. Living Media India Limited and another (2012) 3 SCC 563, holding that the doctrine of liberal approach cannot be invoked to condone inordinate delays in the absence of an acceptable explanation.

The court reasoned that while a liberal approach is generally adopted for Section 5 applications, "sufficient cause" cannot be construed so broadly as to cover inordinate and unexplained delays.

In evaluating the 662-day delay, the court found the appellant’s justifications—specifically the plea of lack of knowledge and reliance on counsel—to be general in nature and lacking specific particulars.

The court noted that the appellant failed to provide any cogent material or supporting evidence to substantiate the claim that he was unaware of the proceedings or the award.

Consequently, the court held that the appellant failed to satisfactorily explain each day’s delay, and the reasons assigned did not meet the legal threshold of "sufficient cause".

The court rejected I.A. No. 7431/2010 and, as a consequence, dismissed the miscellaneous appeal as being barred by limitation.

No order was made as to costs.