Condonation of delay: liberal construction of sufficient cause permits condonation where sanction delay caused prompt filing thereafter.

Condonation of delay addresses a 3-year-and-10-day delay where a public authority awaited internal sanction before filing first appeal; the legal principle applied is a liberal construction of "sufficient cause" permitting procedural latitude for governmental decision-making where no gross negligence or mala fide conduct exists. Because sanction was sought and received and the appeal was filed promptly thereafter, the authority for condonation is satisfied and the appeal was restored subject to payment of costs and an order to appear before the First Appellate Court on the specified date.

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Issues: Whether the delay of 3 years and 10 days in filing the first appeal by the public authority should be condoned.

Analysis: The petitioner, a public authority, sought sanction from its head office to file the appeal within the period of limitation; the sanction remained pending for over three years and was received on 16.08.2017, after which the appeal was filed immediately. There is no material that the First Appellate Court called upon the petitioner to produce supporting documents, nor is there evidence of gross negligence, deliberate inaction or lack of bona fides by the petitioner. Established principles require liberal construction of "sufficient cause" and permit some latitude for procedural delays inherent in governmental functioning where public interest and institutional decision-making are involved. Applying these principles to the facts, and noting that the petitioner filed the appeal promptly on receipt of sanction, the conditions for condonation are satisfied.

Conclusion: Delay of 3 years and 10 days is condoned; the appeal is restored subject to payment of costs of Rs. 5,000 and directions to appear before the First Appellate Court on 19 December, 2022.

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