Condonation of delay in review: post-limitation developments and internal approvals do not constitute sufficient cause.

Delay of 417 days in filing review applications was held not condonable because the Department had to decide within the 30-day limitation period whether to seek review. Waiting for developments in other matters and later obtaining internal approvals were matters arising after expiry of limitation and could not amount to sufficient cause. Applying the settled principles on delay and the State's obligation to act with diligence, the explanation was found unsatisfactory and the review applications were rejected.

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Issues: Whether the delay of 417 days in filing the review applications was liable to be condoned on the ground of sufficient cause.

Analysis: The applications were founded on the plea that the Department awaited developments concerning other matters and later pursued internal approvals before seeking review. The Court held that, where filing of a special leave petition was barred by the monetary threshold and the limitation period for review was 30 days, the Department was required to decide within limitation whether to seek review. Events occurring after expiry of limitation could not constitute sufficient cause for condonation. Applying the governing principles on delay and the obligation of the State to act with diligence, the explanation offered was found unsatisfactory.

Conclusion: The delay was not condonable and the review applications were rejected.

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