Liberal construction of sufficient cause under limitation law upheld for government litigation delay in land acquisition appeals

Section 5 of the Limitation Act requires "sufficient cause" to be construed liberally where delay is not marked by gross negligence, deliberate inaction or lack of bona fides. In government litigation, some latitude is permissible because delay may stem from the realities of official decision-making and the conduct of law officers, though greater diligence remains expected. Applying that approach, the Supreme Court accepted that the High Court had exercised its discretion on a permissible view of the facts, including the predicament created by the law officers' conduct. The High Court's condonation of delay in filing the land acquisition appeals was upheld.

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Issues: Whether the High Court was justified in condoning the delay under Section 5 of the Limitation Act, 1963 in filing the land acquisition appeals.

Analysis: The expression "sufficient cause" in Section 5 calls for a liberal construction so that substantial justice is advanced, and delay may be condoned where no gross negligence, deliberate inaction, or lack of bona fides is attributable to the party seeking relief. In matters involving Government litigation, the Court recognised that public interest may be affected by the acts or omissions of law officers, and that some latitude is permissible having regard to the realities of governmental decision-making. Although the Government's conduct was noted to be close to inaction and greater diligence was expected, the circumstances disclosed a predicament created by the conduct of its law officers and the High Court had exercised its discretion on a permissible view of the facts.

Conclusion: The High Court's condonation of delay was upheld and the challenge to that order failed.

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