Liberal condonation of delay requires a merits-focused approach; time-bar dismissal set aside where explanation was not properly considered.

The Tribunal's refusal to entertain the appeal as time-barred was unsustainable because it did not properly consider the affidavit-supported explanation for delay or the settled liberal approach to condonation. The governing principle is that "sufficient cause" must be construed to advance substantial justice, and technical limitation should not defeat merits where the delay is not shown to be deliberate, mala fide, or part of a dilatory strategy. The HC set aside the time-bar dismissal and restored the matter for fresh adjudication on merits.

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Issues: (i) Whether the Tribunal was justified in dismissing the appeal as time-barred without properly considering the explanation for delay and the settled law on condonation of delay.

Analysis: The delay question was the only issue substantively decided. The explanation for delay was supported by affidavit, and the governing principle is that the expression "sufficient cause" must receive a liberal construction to advance substantial justice. Technical considerations should not defeat adjudication on merits where the delay is not shown to be deliberate, mala fide, or part of a dilatory strategy. The Tribunal was found to have ignored the controlling approach laid down by the Supreme Court on condonation of delay and substantial justice.

Conclusion: The dismissal of the appeal as time-barred was held unsustainable. The order of the Tribunal was set aside and the matter was remanded for decision on merits.

Final Conclusion: The revision succeeded to the extent of setting aside the time-bar dismissal, and the appeal was restored to the Tribunal for fresh adjudication on merits.

Ratio Decidendi: An explanation for delay must be assessed liberally where substantial justice so requires, and an appeal should not be rejected on technical limitation grounds unless the delay is shown to be unjustified or mala fide.

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