Condonation of delay under limitation law turns on sufficient cause after the last filing date, not the entire limitation period.

For condonation of delay under section 5 of the Indian Limitation Act, 1908, the applicant need not explain conduct throughout the entire limitation period. The relevant inquiry is whether sufficient cause existed for not filing on the last day of limitation and whether the delay thereafter is satisfactorily explained. General criticism of lack of diligence during the whole period is not, by itself, a ground to refuse condonation under section 5, though broader bona fides and diligence may arise under section 14 or a combined application of sections 5 and 14. The one-day delay was condoned, and the appeal was remitted for disposal on merits.

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Issues: Whether, for purposes of condonation of delay under section 5 of the Indian Limitation Act, 1908, the applicant must explain its conduct throughout the entire period of limitation or only the delay after the last date for filing the appeal.

Analysis: Section 5 permits an appeal to be admitted after the prescribed period when sufficient cause is shown for not preferring it within such period. The expression was construed in the context of the object of limitation law, namely, that expiry of the limitation period creates a vested advantage for the decree-holder, while section 5 confers a discretionary power to advance substantial justice where sufficient cause is proved. The relevant inquiry under section 5 is whether the appellant had sufficient cause for not filing the appeal on the last day of limitation and, if so, whether the delay thereafter is satisfactorily explained. General criticism of lack of diligence during the whole limitation period is not by itself a valid ground to refuse condonation under section 5. The Court distinguished authorities where the broader requirements of bona fides and diligence arose in the context of section 14 or combined operation of sections 5 and 14.

Conclusion: The appellant was not required, for section 5 alone, to explain its conduct throughout the whole limitation period, and the one-day delay was liable to be condoned. The appeal was therefore allowed and remitted for disposal on merits.

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