Sufficient cause for government delay rejected where administrative lethargy and vague explanations failed to justify late filing.

A Government appeal filed 16 days late was held not to satisfy the test of sufficient cause under the appellate limitation rule. The Tribunal found that only the post-limitation delay was relevant, but the explanation showed lethargic and mechanical movement of the file, no convincing reason for the period after approval, and no unavoidable administrative difficulty. Holidays and last-day typing outside the office did not account for the delay, and the liberal approach applied in other government-delay cases was distinguished because no comparable collective decision-making process was shown. The appeal remained barred by limitation and was not entertained.

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Issues: Whether the delay of 16 days in filing the appeal could be condoned on the ground of sufficient cause under the relevant appellate provision.

Analysis: The Tribunal held that, although only the delay after expiry of limitation was relevant, the explanation offered did not show sufficient cause. The file had moved in a lethargic and mechanical manner, no convincing reason was shown for the time taken after approval, and the mere fact that certain days were holidays or that the papers were typed outside the office on the last day did not explain the delay. The Tribunal distinguished the authorities relied upon for liberal treatment of governmental delay and found that no comparable collective decision-making process or unavoidable administrative difficulty was demonstrated. It also emphasised that negligence and lack of urgency could not be ignored in assessing sufficiency of cause.

Conclusion: The delay was not condoned and the application was rejected.

Final Conclusion: The appeal could not be entertained because it remained barred by limitation.

Ratio Decidendi: Delay in filing an appeal by the Government is not condonable unless a convincing and specific explanation shows sufficient cause for the delay after limitation expires, and administrative lethargy or avoidable inaction does not satisfy that test.

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