Liberal construction of sufficient cause supports condonation where an appeal was filed in the wrong forum by bona fide mistake.

Delay in presenting an appeal may be condoned under Section 5 of the Limitation Act where the appellant initially filed in the wrong forum under a bona fide mistake and acted with reasonable diligence. The expression "sufficient cause" is to be construed liberally to advance substantial justice, especially where there is no negligence, inaction, or lack of bona fides. Circumstances akin to prosecution in the wrong court may be relevant in assessing sufficient cause, with the equitable considerations underlying Section 14 informing the Section 5 inquiry. On that approach, refusal to condone delay was not justified.

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Issues: Whether the delay in presenting the appeal before the proper court should be excused under Section 5 of the Limitation Act on the ground that the appeal had initially been filed in the wrong forum under a bona fide mistake and with reasonable diligence.

Analysis: The petitioner filed the appeal in the High Court under a genuine but mistaken impression as to the proper appellate forum. The record included an observation that there was bona fide doubt in the petitioner's mind about the correct court. The governing principle is that delay may be excused where the appellant has acted with reasonable diligence and where the expression "sufficient cause" is to be construed liberally so as to advance substantial justice, particularly when there is no negligence, inaction, or lack of bona fides. The circumstances were treated as analogous to cases where proceedings are prosecuted in the wrong court and the equities underlying Section 14 of the Limitation Act may be considered in judging sufficient cause under Section 5.

Conclusion: The delay ought to have been excused and the revisional court was justified in interfering with the refusal to condone delay.

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