Sufficient cause for condonation of delay may be shown by later material explaining a delayed decision to appeal.

Delay in filing an appeal under Section 25 of the Sick Industrial Companies (Special Provisions) Act, 1989 is condonable only on sufficient cause, measured from communication of the order. Although the initial explanation for the seven-day delay was found inaccurate and inadequate because it did not account for the time after receipt of the authenticated copy, later material showed that the authority had first accepted the order and then decided to challenge it on revenue grounds. That additional material supplied sufficient cause, and the delay was condoned.

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Issues: Whether the delay of seven days in filing the appeal before the Appellate Authority for Industrial and Financial Reconstruction under Section 25 of the Sick Industrial Companies (Special Provisions) Act, 1989 deserved condonation.

Analysis: The statutory period under Section 25 runs from communication of the order, and the appeal was filed beyond forty-five days from the relevant date. The reason set out in the condonation application was found to be inaccurate and, by itself, insufficient because it did not explain why the appeal could not be filed within time after receipt of the authenticated copy. At the same time, the material subsequently brought on record showed that the authority had initially accepted the order and later decided to challenge it on revenue grounds. In view of that additional material, the delay was held to be supported by sufficient cause.

Conclusion: The delay of seven days was rightly condoned.

Ratio Decidendi: For condonation of delay, the decisive test is sufficient cause, and later-disclosed material explaining the delayed decision to appeal can justify condonation even where the original explanation was inadequate.

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