Liberal construction of sufficient cause supports condonation of substitution delay and setting aside abatement for merits-based adjudication.

The expression "sufficient cause" under the Limitation Act should receive a liberal and pragmatic construction where delay in substitution and a prayer to set aside abatement are concerned, so that substantial justice is not defeated by a pedantic or hyper-technical approach. The stated principle is that courts should prefer adjudication on merits when the delay explanation is otherwise acceptable. On that basis, the substitution-related petitions were treated as maintainable, the delay was condoned, the abatement was set aside, and the legal heirs of the deceased defendant were allowed to be brought on record.

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Issues: Whether the delay in taking steps for substitution and the consequent prayer to set aside abatement ought to be condoned and allowed so that the legal heirs of the deceased defendant could be brought on record.

Analysis: The Court applied the settled principle that the expression "sufficient cause" in Section 5 of the Limitation Act, 1963 must receive a liberal and pragmatic construction so that substantial justice is advanced. It held that delay should not be approached in a pedantic or hyper-technical manner, particularly where refusal to condone delay would defeat adjudication on merits. On that basis, the rejection of the substitution-related petitions was found to be inconsistent with the justice-oriented approach required in such matters.

Conclusion: The delay was condoned, the abatement was set aside, and the application for substitution was allowed in favour of the petitioners.

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