Liberal construction of sufficient cause supports condonation where postal transit delay causes only a marginal lapse in filing appeals.

'Sufficient cause' for condonation of delay must be construed liberally to advance substantial justice, and an applicant need not explain conduct throughout the entire limitation period. Where there is no negligence, inaction or lack of bona fides, delay caused by postal transit may justify condonation. On the facts, the Revenue had dispatched the appeals five days before limitation expired, the marginal delay was attributed to postal transit, and the delay was condoned on that basis. The prior Orissa High Court decision was distinguished on its facts, while later authority supporting condonation for unusual postal delay was followed.

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Issues: Whether a delay of 2 days in filing five appeals by the Revenue should be condoned on the ground that the appeals were dispatched by registered post 5 days before expiry of limitation and were delayed in postal transit.

Analysis: The governing principle is that the expression "sufficient cause" must receive a liberal construction so as to advance substantial justice, and the applicant is not required to explain its conduct throughout the entire limitation period. Where there is no negligence, inaction, or want of bona fides, delay attributable to postal transit may be accepted as sufficient cause. The earlier Orissa High Court decision relied upon by the respondents was distinguished on its facts, while the later decision in Kella Appalaswamy and Sons was treated as supporting the view that unusual postal delay and absence of negligence can justify condonation. The dispatch of the appeals 5 days before expiry, the practical working of Government, and the need to avoid defeating substantial justice on a marginal delay were treated as material considerations.

Conclusion: The delay of 2 days was condoned and the applications for condonation were allowed.

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