Liberal construction of sufficient cause supports condonation where delay is short and explanation is bona fide.

A four-month delay in filing a reference application was treated as capable of condonation where the explanation was found plausible and bona fide. The governing principle is that "sufficient cause" under the Limitation Act must receive a liberal construction, particularly when the delay is short, so that substantial justice is not defeated by a technical approach. Condonation remains fact-specific and turns on whether the applicant acted with due care and caution and whether the delay occurred beyond its control. On that basis, the delay was sufficiently explained and should have been condoned.

---

---

Issues: Whether the delay of four months in filing the reference application deserved condonation under Section 5 of the Limitation Act, 1963.

Analysis: The explanation for the delay was found to be plausible and bona fide. The governing principle is that the expression "sufficient cause" must receive a liberal construction where the delay is short, while the Court must ensure that substantial justice is not defeated by a pedantic or technical approach. Condonation depends on the facts of each case and requires a judicial assessment whether the delay occurred despite due care and caution and was beyond the applicant's control.

Conclusion: The delay was sufficiently explained and ought to have been condoned.

---