Condonation of delay requires a satisfactory, fact-specific explanation; routine departmental excuses do not justify late appeals.

Delhi HC held that condonation of delay under Section 5 of the Limitation Act requires a fact-sensitive, satisfactory explanation, and routine or vague departmental statements are insufficient even for the State. An explanation that papers and court-fee arrangements took time, without particulars or convincing cause, was treated as unsatisfactory; the Court rejected a blanket liberal approach for mechanically delayed appeals and stressed that habitual administrative negligence and cyclostyled explanations do not justify indulgence. The delay was not condoned, and the land acquisition appeal was treated as barred by limitation.

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Issues: Whether the delay of eighty days in filing the land acquisition appeal should be condoned under Section 5 of the Limitation Act read with Section 151 of the Code of Civil Procedure, 1908, and whether the appeal was barred by limitation.

Analysis: The explanation offered for the delay was found to be routine and unsatisfactory, resting only on a general assertion that departmental papers and court-fee arrangements took time. The Court stressed that although the law of limitation applies equally to the State and private litigants, the discretion to condone delay must be exercised with commonsense, balancing substantial justice, public interest, and the facts of each case. It distinguished precedents involving nominal delay or exceptional facts and held that they could not justify a blanket liberal approach in a large class of mechanically delayed appeals filed without particulars or convincing cause. The Court further observed that habitual administrative negligence and cyclostyled explanations do not constitute a satisfactory basis for indulgence.

Conclusion: The delay was not satisfactorily explained, the application for condonation was rejected, and the appeal was held to be barred by limitation.

Ratio Decidendi: Condonation of delay depends on a fact-sensitive exercise of discretion on a satisfactory showing of cause, and routine or vague departmental explanations are insufficient even for the State.

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