Vague, routine, and unverifiable explanations do not justify condonation of limitation delay.

The appellants, Liberty General Insurance Ltd. and its Ranchi branch, sought to challenge the Judgment and Award dated 27 January 2025 passed by the Motor Accident Claims Tribunal, Bermo at Tenughat, in Motor Accident Claim Case No. 137 of 2020, which awarded compensation of ₹14,03,820 to the claimants.

The accompanying appeal was filed with a delay of 204 days, for which the appellants filed I.A. No. 16005 of 2025 seeking condonation of delay.

The appellants attributed the delay to obtaining the counsel’s opinion, transmission of files, scrutiny by officers at different administrative locations, and completion of internal procedural formalities and sanctions.

The claimants had also initiated execution proceedings, and the awarded amount had not been deposited despite the Tribunal’s directions.

Whether the 204-day delay in filing the appeal should be condoned on the basis of the general and unspecified explanations offered by the appellant-insurance company?

Whether, following dismissal of the delay-condonation application and the appeal, the appellant should be directed to deposit the entire awarded amount with interest within a specified period?

The Court applied the principle governing condonation of delay under the law of limitation, namely that delay must be explained through specific, credible, and verifiable facts, and that vague assertions of administrative or procedural delay do not constitute sufficient cause.

It relied on Postmaster General v. Living Media India Ltd., (2012) 3 SCC 563, for the proposition that the law of limitation binds all litigants equally and that bureaucratic or institutional delay cannot routinely be accepted, particularly when modern communication and administrative facilities are available.

The Court further held that insurance companies are not entitled to any special or extended limitation period merely because their head or administrative offices are situated at different places.

The Court found that the appellants had failed to provide dates or particulars showing when the award was received, when legal advice was obtained, when the file was transmitted, or how the alleged examination by several officers caused the 204-day delay.

Statements that the delay resulted from circumstances beyond the appellant’s control and from completion of internal sanctions were considered vague, routine, and unverifiable.

Applying the principle that limitation applies equally to all litigants, the Court rejected the insurance company’s reliance on internal administrative processes, especially since it was a private commercial entity.

The Court also considered that continued non-payment caused substantially greater prejudice to the accident claimants than any prejudice to the insurer from depositing the award.

The merits of the proposed appeal could not be considered while deciding the application for condonation of delay.

Consequently, the accompanying appeal and connected interlocutory applications were dismissed without costs.

The appellant-insurance company was directed to deposit the entire awarded amount, together with interest, before the Executing Court within two weeks.

The Executing Court was directed to immediately disburse the deposited amount to the claimants through regular banking channels, and the appellants were required to file a compliance report by 1 October 2026.

The matter was directed to be listed on 9 October 2026, and the statutory deposit was to be refunded upon proof of compliance.