Condonation of delay in statutory appeals may be granted where sufficient cause exists and merits-based adjudication would otherwise be defeated.

Delay in filing a statutory appeal may be condoned when sufficient cause is shown and refusal would defeat adjudication on merits and cause prejudice. Applying this principle to an appeal filed 356 days late under the limitation regime in the Finance Act, 1994, the Court treated the petitioner's explanation as adequate, preserved the appellate remedy, and ordered the appeal to be heard on merits. The ruling emphasises that condonation should advance substantial justice where the delay is attributable to circumstances beyond the appellant's control and denial of relief would shut out merits-based consideration.

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Issues: Whether the delay of 356 days in filing the statutory appeal should be condoned and the appeal directed to be heard on merits.

Analysis: The appeal was filed beyond the limitation prescribed under Section 85 of the Finance Act, 1994, but the delay arose from circumstances stated to be beyond the petitioner's control. The Court followed its consistent view that, where sufficient cause is shown and refusal to condone delay would prevent adjudication on merits and cause prejudice, the appellate remedy should be preserved by condoning the delay.

Conclusion: The delay was condoned and the appellate authority was directed to entertain the appeal and decide it on merits.

Ratio Decidendi: Where sufficient cause is shown for delayed filing of an appeal under the statutory limitation regime, and denial of condonation would defeat adjudication on merits, the delay may be condoned to advance substantial justice.

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