Condonation of delay requires sufficient cause and cannot rest on unexplained laches, even when the applicant is the State

Condonation of delay under Section 5 of the Limitation Act, 1963 depends on a real and satisfactory explanation showing sufficient cause; a liberal approach does not cure unexplained laches or negligence. Applied to a delayed revision against rejection of an objection under Section 47 CPC, the State's failure to challenge the earlier order in time and its attempt to wait until execution steps were taken did not amount to sufficient cause, so the delay could not be condoned and the condonation order was unsustainable.

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Issues: Whether the delay in filing the revision petition against the order rejecting the objection under Section 47 of the Code of Civil Procedure, 1908 could be condoned on the facts of the case.

Analysis: The governing principle is that the expression "sufficient cause" must be applied with a pragmatic and justice-oriented approach, and a liberal view is ordinarily taken in matters of delay. At the same time, condonation is not automatic and cannot be granted where there is serious laches, negligence, or absence of a satisfactory explanation. The State had earlier filed an objection under Section 47 of the Code of Civil Procedure, 1908, which was rejected, and it did not challenge that order within time. Instead, it waited until execution steps were taken and then sought to assail the earlier order with a delayed revision. The explanation offered did not disclose sufficient cause, and the High Court failed to consider the effect of the State's unexplained delay and repeated objections.

Conclusion: The delay was not liable to be condoned and the order condoning delay was unsustainable.

Final Conclusion: The appellate court declined to extend the benefit of condonation where no sufficient cause was shown, and restored the consequence that the delayed revision could not proceed.

Ratio Decidendi: Condonation of delay under Section 5 of the Limitation Act, 1963 requires a real and satisfactory explanation amounting to sufficient cause, and a liberal approach cannot override unexplained laches and negligence, even when the applicant is the State.

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