Delay in filing SLP against s.264 revision order by State body, condonation refused; SLP dismissed as time-barred.

The dominant issue was whether an inordinate delay in filing an SLP against an order concerning revision under s. 264 could be condoned. Applying its strict approach to limitation, the SC held that the explanation tendered was unsatisfactory and reiterated that State instrumentalities are not entitled to extra leniency for lethargic or negligent conduct, and cannot effectively create their own limitation periods contrary to statute. The application for condonation of delay was rejected, and the SLP was dismissed solely on the ground of delay.

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The Supreme Court dealt with a special leave petition filed with a delay of 448 days. The petitioner sought condonation of delay, but the Court, after examining the explanation, found it unsatisfactory and declined to condone the delay. Relying on the precedent in *Shivamma (Dead) by LRs v. Karnataka Housing Board & Ors.*, 2025 SCC OnLine SC 1969, the Court reiterated that "delay in filing petitions/ appeals by State or its instrumentalities is not to be condoned by showing extra leniency for lethargic and negligent attitude of their officers who tend to carve out their own periods of limitation having little regard for the limitation period specified in the statute or the rules." On this basis, the delay condonation application was rejected, and the special leave petition was dismissed as barred by limitation. Pending applications were disposed of.

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