Condonation of delay requires a pleaded, credible explanation; an afterthought cannot cure a time-barred appeal.

An appeal filed beyond the sixty-day period under section 20(1) was treated as time-barred where the dealer could not displace service of the section 11(3) notice sent by registered acknowledgment due post. The plea that notice was not served on an authorised person or was sent to an incorrect address did not defeat the limitation finding. Condonation was refused because the explanation for delay was not pleaded in the memorandum of appeal, no contemporaneous application was made, and the illness-based medical certificate was viewed as an afterthought. The governing principle is that delay must be bona fide, specifically pleaded, and supported by credible material.

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Issues: Whether the dealer's appeals were barred by limitation and whether the delay in filing the appeals deserved condonation.

Analysis: The limitation period for an appeal under section 20(1) was sixty days from receipt of the notice issued under section 11(3). The notices had been sent by registered acknowledgment due post, and the plea that they were not served on an authorised person or were sent to an incorrect address did not displace the finding that the appeals were time-barred. The plea that the dealer learnt of the assessment later, obtained certified copies on 18 May 1976, and filed the appeals on 16 August 1976 was not pleaded in the memorandum of appeal. No contemporaneous request for condonation had been made, and the medical certificate relied on for illness was treated as an afterthought.

Conclusion: The delay was not shown to be bona fide or satisfactorily explained, and condonation was rightly refused.

Final Conclusion: The limitation objection succeeded, and the appeals failed on the ground of unexplained delay.

Ratio Decidendi: A party seeking condonation must disclose and substantiate the cause of delay with contemporaneous pleadings and credible material; a later-invented explanation may be rejected as an afterthought.

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