Limitation Act, 1963 — Section 5
Condonation of delay — “Sufficient cause” — Scope
Delay can be condoned only on proof of “sufficient cause” — The expression means an adequate and enough reason which prevents a party from approaching the Court within limitation — Negligence, inaction or lack of bona fides cannot constitute sufficient cause.
[Paras 9, 11, 15]
Limitation Act, 1963 — Section 5
Condonation of delay — “Sufficient cause” — Scope
Delay can be condoned only on proof of “sufficient cause” — The expression means an adequate and enough reason which prevents a party from approaching the Court within limitation — Negligence, inaction or lack of bona fides cannot constitute sufficient cause.
[Paras 9, 11, 15]
Limitation — Inordinate delay — Discretion of Court
Where delay is gross and unexplained, Court has no jurisdiction to condone the same — Discretion under Section 5 must be exercised judiciously and not on sympathetic or equitable considerations.
[Paras 6, 15, 16]
Equality — Article 14 — Negative equality
Article 14 does not permit perpetuation of illegality — Erroneous or illegal orders passed in other cases cannot be relied upon to claim similar relief — Doctrine of negative equality is impermissible.
[Para 8]
Limitation — Conditional condonation — Illegality
Condoning delay by imposing conditions (such as denial of interest for the delay period) without recording satisfaction of “sufficient cause” is impermissible — Such orders are contrary to statutory mandate.
[Paras 7, 15]
Limitation law — Mandatory application
“Dura lex sed lex”
Law of limitation must be applied with full rigour — Courts have no power to extend limitation on equitable or sympathetic grounds — Hardship is irrelevant where statute is clear.
[Paras 12, 13]
Public policy — Limitation statutes
Limitation statutes are founded on public policy to ensure certainty, suppress stale claims, and compel diligence — Courts cannot dilute legislative intent by judicial discretion.
[Paras 12, 13]
Land Acquisition Act, 1894 — Section 54
Appeal — Delay
Appeals under Section 54 are governed strictly by limitation — Inordinate delay of more than five years, without satisfactory explanation, is fatal.
[Paras 1–6, 16]
II. ANALYSIS OF LAW
A. Meaning of “Sufficient Cause”
The Court undertakes an authoritative exposition of the expression “sufficient cause” and holds that:
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It must be adequate, bona fide, and reasonable;
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It excludes negligence, inaction, or casual conduct;
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The applicant must establish that delay was unavoidable despite due diligence (Paras 9–11).
The Court reiterates that while interpretation may be liberal, it cannot be elastic to the point of defeating limitation law.
B. Judicial Discretion under Section 5
The discretion to condone delay is not unfettered. The Court stresses that:
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Discretion must be exercised strictly within statutory parameters;
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Courts cannot substitute sympathy for legal standards;
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Absence of sufficient cause ousts jurisdiction to condone delay (Paras 15–16).
C. Rejection of “Parity” Argument
A central issue addressed is the plea that other similarly placed litigants had obtained condonation. The Court unequivocally holds:
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Article 14 does not envisage negative equality;
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Illegal or erroneous orders cannot form the basis for claiming similar relief;
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Illegality cannot be multiplied by judicial endorsement (Para 8).
D. Conditional Condonation — Disapproved
The Court strongly disapproves the practice of condoning delay by imposing conditions such as:
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Denial of interest for the delay period.
Such orders, without first establishing sufficient cause, are held to be illegal and jurisdictionally flawed (Paras 7, 15).
E. Limitation as Public Policy
The judgment reiterates the foundational rationale of limitation law:
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To prevent uncertainty and stale litigation;
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To ensure diligence and repose;
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To protect settled rights.
Courts are reminded that they cannot dilute statutory limitation on equitable grounds (Paras 12–13).
III. ANALYSIS OF FACTS (AS FOUND)
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Land acquisition awards were passed between 1997–2002 (Paras 1–2).
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Appeals under Section 54 of the Land Acquisition Act were filed in 2007, with a delay of about 5½ years (Para 6).
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Sole explanation offered was illness of one appellant (Paras 3, 6).
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High Court rejected applications for condonation of delay (Para 2).
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Appellants relied on earlier High Court orders condoning delay conditionally (Para 7).
IV. FINAL HOLDING / RESULT
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No sufficient cause shown for inordinate delay.
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Article 14 plea rejected.
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Conditional condonation practice disapproved.
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Appeals dismissed; High Court order affirmed.
[Para 16]
Ratio (Concise)
Condonation of delay is a matter of jurisdictional discretion confined strictly to proof of “sufficient cause”; courts cannot condone inordinate delay on equitable grounds, impose conditions in lieu of statutory compliance, or perpetuate illegality by invoking Article 14.
