Liberal construction of sufficient cause allowed condonation of delay in State litigation, but only with exemplary costs

The expression "sufficient cause" under the Limitation Act is to be construed liberally where substantial justice and public interest are at stake, and some latitude may be allowed in State litigation because of slower governmental decision-making. Even so, such latitude is not unlimited, and a casual or lethargic explanation for delay remains relevant. Balancing the delay against the questions of law and the larger public interest involved, the Court condoned the delay in filing the special leave petitions, but only subject to payment of exemplary costs.

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Issues: Whether the inordinate delay in filing the special leave petitions could be condoned on showing sufficient cause, having regard to the governmental nature of the litigation and the need to protect public interest.

Analysis: The expression "sufficient cause" under Section 5 of the Indian Limitation Act, 1963 is to receive a liberal construction where substantial justice is at stake. In matters involving the State, some latitude may be permissible because governmental decision-making is often slowed by procedural delay, though such latitude is not unlimited. The explanation for the delay showed a casual and lethargic handling of the matter, but the Court found the questions of law and the large public interest involved to be relevant factors. To balance these considerations, the Court condoned the delay subject to payment of exemplary costs.

Conclusion: The delay was condoned in favour of the appellant-State, subject to payment of costs.

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