Vague, routine and unverifiable reasons cannot justify condonation of delay by insurers.

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. 138 of 2020, awarding compensation of ₹9,45,120 to the claimants.

The appeal was filed with a delay of 204 days, and the appellants moved I.A. No. 16003 of 2025 seeking condonation of that delay.

The appellants attributed the delay to the time taken in obtaining the opinion of counsel, transferring files, examination of records by officers at different administrative locations, and completing internal procedural formalities and sanctions.

The claimants had also initiated execution proceedings, despite which the insurer had not deposited the awarded amount within the time directed by the Tribunal.

Whether the appellants had shown sufficient and specific cause for condoning the 204-day delay in filing the appeal against the Motor Accident Claims Tribunal’s award?

Whether vague explanations based on internal administrative processing, inter-office communication, and obtaining sanctions could constitute circumstances beyond the insurer’s control and justify condonation of delay?

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

The Court applied the principles governing condonation of delay under the law of limitation, requiring an applicant to disclose a specific, credible, and sufficient cause for each material period of delay.

Routine, vague, and unverifiable explanations relating to administrative or bureaucratic processes do not ordinarily constitute sufficient cause, particularly where the applicant is a private commercial entity.

The Court relied on Postmaster General v. Living Media India Ltd., (2012) 3 SCC 563, for the principle that the law of limitation binds all parties equally and that bureaucratic delay cannot be routinely accepted as justification in view of modern administrative and technological facilities.

The Court also considered the relative prejudice to motor-accident claimants, who are entitled to timely satisfaction of awards, against the prejudice to an insurer from refusal to condone an inadequately explained delay.

The Court found that the appellants had not stated the date on which they received the award, when legal advice was obtained, when the file was forwarded, or how much time was consumed at each stage.

The assertions that the matter was monitored from Kolkata, that several officers examined the record, and that sanctions were required were held to be general statements unsupported by particulars or verification.

The Court rejected the contention that the location of the insurer’s head or administrative offices could justify a separate or relaxed limitation period, observing that the insurer was a private-sector commercial entity and could not rely on bureaucratic delay.

Given the greater prejudice caused to accident victims by continued non-payment of compensation, the Court held that the unexplained 204-day delay could not be condoned.

The merits of the proposed appeal were not considered because the grounds of appeal could not be examined at the stage of deciding the application for condonation of delay.

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

The insurer was directed to deposit the entire awarded amount of ₹9,45,120 together with interest before the executing court within two weeks, and the executing court was directed to disburse the amount to the claimants through regular banking channels.

The appellants were required to file a compliance report by 1 October 2026; the matter was listed for 9 October 2026 to consider compliance.

The statutory deposit was ordered to be refunded upon production of proof of deposit of the entire award amount with interest.