Liberal condonation of delay applies where poverty and illiteracy explain the filing lapse, requiring decision on merits.

Applications for condonation of delay should ordinarily be approached liberally so disputes are decided on merits rather than technicalities. The Court accepted that poverty, ignorance, inability to arrange legal fees, and illiteracy can constitute a sufficient explanation, and held that only unexplained gross negligence or an ulterior motive justifies refusal. Applying that principle, it found the Tribunal had proceeded on wrong principles and committed a jurisdictional error in treating the revision as time-barred without condoning delay. The refusal to condone delay was therefore unsustainable, and the matter was remanded for restoration of the revision and decision on merits.

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Issues: Whether the Tribunal was justified in refusing to condone the delay in filing the revisional application and in dismissing the revision as time-barred instead of deciding it on merits.

Analysis: The petition was under Article 227 of the Constitution of India challenging the Tribunal's rejection of the revision on limitation. The delay was explained on the grounds of poverty, ignorance, inability to arrange legal fees, and illiteracy. The Court applied the settled principle that applications for condonation of delay must ordinarily receive a liberal approach so that disputes are decided on merits rather than technicalities. It relied on binding precedent emphasizing that poverty, ignorance, and illiteracy may constitute sufficient explanation and that unexplained gross negligence or ulterior motive is the relevant disqualifying factor. The Court held that the Tribunal acted on wrong principles, which amounted to a jurisdictional error, and therefore its refusal to condone delay could not stand.

Conclusion: The refusal to condone delay was held unsustainable and the Tribunal's order was set aside, with the matter remanded for restoration of the revision and decision on merits.

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