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Issues: Whether ignorance of law could constitute sufficient cause for condonation of delay under the second proviso to section 15(2) of the Payment of Wages Act, and whether the applicants were required to explain the delay for the entire period up to the filing of the applications.
Analysis: The proviso required the applicant to satisfy the authority that there was sufficient cause for not making the application within six months. The Court held that the expression was to be construed on the same principle as section 5 of the Limitation Act, so that the explanation must cover the whole period of delay. Even assuming that ignorance or mistake of law could in a proper case amount to sufficient cause, the applicants still had to explain their inaction after they became aware of the relevant legal position. The authority had found, as a matter of fact, that no satisfactory explanation was given for the delay after the date when the position under section 70 of the Bombay Shops and Establishments Act had become clear, and that finding was fatal to the claim.
Conclusion: The plea for condonation of delay failed because the entire period of delay was not satisfactorily explained.
Ratio Decidendi: Under a proviso requiring sufficient cause for not making an application within the prescribed period, the applicant must account for the whole period of delay, and failure to explain any material part of that delay defeats condonation.