Liberal construction of sufficient cause led to condonation of a long tax appeal delay where public revenue was at stake.

A 924-day delay in filing a tax appeal was condoned because the State explained the lapse through administrative file movement, internal approvals and drafting time. The Court applied a liberal, justice-oriented construction of "sufficient cause", noting that government litigation proceeds through an impersonal and time-consuming process and that the dispute involved a section 80 determination under the Gujarat VAT Act with potential permanent revenue impact. The civil application was allowed, and costs were imposed on the State.

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Issues: Whether a delay of 924 days in filing the tax appeal should be condoned on the basis of administrative processing, substantial question of law, and the revenue impact involved.

Analysis: The delay was explained as arising from governmental administrative movement of the file and the time taken in obtaining internal approvals and drafting the appeal. The Court noted that the dispute concerned a determination under section 80 of the Gujarat VAT Act, which had finality and could have a permanent effect on tax collection if not challenged. In considering condonation, the Court applied the settled approach that the expression "sufficient cause" must receive a liberal and justice-oriented construction, especially where public revenue is at stake and the State machinery works through an impersonal and time-consuming process.

Conclusion: The delay was condoned and the civil application was allowed, with costs imposed on the applicant State.

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