The Calcutta High Court dismissed an appeal filed by the Andaman and Nicobar Administration and others due to a delay of 234 days, which was not condoned because the appellants failed to provide a satisfactory explanation. The appeal, which was related to a decision dated November 11, 2024, was filed on August 20, 2025, after an unexplained delay of over a month in applying for the certified copy of the order. The appellants attributed the delay to administrative processing and the need for departmental approvals but did not offer a detailed day-to-day account of the delay.
The primary issue was whether general explanations of administrative delays could be considered "sufficient cause" under Section 5 of the Limitation Act, 1963. The High Court ruled that for condonation of delay, a specific, cogent, and satisfactory explanation is required, supported by detailed pleadings. The Court found the appellants' reasons to be vague and lacking in particulars, failing to justify the day-to-day delay. The decision was influenced by a recent Supreme Court judgment delivered on 5th December, 2025 in Civil Appeal No.14613 of 2025 (Shankargir vs. The State of M.P. and another) that emphasized the need for strict standards in condoning delays.
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As a result of the insufficient explanation, the application for condonation of delay was dismissed, and the appeal was not admitted. Consequently, the Court did not examine the merits of the case. This decision underscores the importance of providing detailed and specific reasons when seeking condonation of delay in legal proceedings.
Parties: The Andaman and Nicobar Administration & Ors. v. Praveen Chandra Biswas
Order Date: 09 January 2026
Facts –
- The appellants filed an appeal with a delay of 234 days, accompanied by an application for condonation under Section 5 of the Limitation Act, 1963.
- The impugned order was passed on 11.11.2024, and the certified copy was applied for after an unexplained delay of more than one month.
- The appeal was ultimately filed on 20.08.2025 without providing a day-to-day explanation for the delay.
- The appellants cited internal administrative processing and departmental approvals as reasons for the delay.
Issue –
- Whether vague and general explanations relating to administrative delay constitute “sufficient cause” for condonation of delay under Section 5 of the Limitation Act.
Order –
- The High Court held that condonation of delay requires specific, cogent, and satisfactory explanation, supported by pleadings.
- The Court found that the reasons cited by the appellants were vague and devoid of particulars, and did not explain the day-to-day delay.
- Reliance was placed on the recent Supreme Court judgment delivered on 5th December, 2025 in Civil Appeal No.14613 of 2025 (Shankargir vs. The State of M.P. and another) clarifying strict standards for condonation of delay.
- The application for condonation of delay was dismissed for failure to show sufficient cause.
- Consequently, the appeal was not admitted, and the Court declined to examine the merits of the case.
