Sufficient cause for substitution delay must be bona fide and diligent, or abatement will not be set aside.

Delay in seeking substitution of a deceased appellant's legal representatives is governed by the requirement of sufficient cause under Order 22 CPC, read with Section 5 of the Limitation Act. The length of delay is not decisive by itself, but the explanation must be reasonable, bona fide, and supported by due diligence. Vague, contradictory, or incomplete explanations indicate negligence and lack of bona fides. Liberal construction of limitation provisions cannot be used to defeat accrued rights of the opposite party. On these principles, the delay was not condoned and abatement was not set aside.

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Issues: Whether the applicants had shown sufficient cause to condone a delay of 778 days in seeking substitution of the legal representatives of the deceased appellant and to set aside the abatement of the appeal.

Analysis: Delay in bringing legal representatives on record under Order 22 of the Code of Civil Procedure is governed by the requirement of sufficient cause, and an application to set aside abatement is to be examined in the light of Section 5 of the Limitation Act, 1963. The length of delay is not decisive by itself, but the explanation must be reasonable, bona fide, and consistent with due diligence. The Court found the explanations in the applications vague and contradictory, noted the absence of true and complete disclosure, and held that the conduct of the applicants showed negligence, inaction, and want of bona fides. The Court also applied the settled principle that liberal construction cannot be extended to the point of defeating the accrued rights of the opposite party.

Conclusion: The applicants failed to establish sufficient cause. The delay was not condoned, the request to bring the legal representatives on record was rejected, abatement was not set aside, and the appeal did not survive.

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