Punjab & Haryana High Court Dismisses Appeal for 102-Day Delay in Filing, Reaffirms That Limitation Law Cannot Be Diluted on Equitable Grounds

Case Name: Pepsu Road Transport Corporation and Another v. Panesary Devi and Another
Date of Judgment: October 9, 2025
Citation: FAO-4562-2025
Bench: Hon’ble Mrs. Justice Sudeépti Sharma

Held: The Punjab & Haryana High Court dismissed an appeal filed with a 102-day delay, holding that the appellants failed to establish sufficient cause to justify condonation under Section 5 of the Limitation Act, 1963. Justice Sudeépti Sharma reiterated that limitation law is founded on public policy and cannot be relaxed merely on sympathetic or equitable grounds. The Court ruled that vague and generalized explanations do not constitute a legally sufficient reason to condone inordinate delay, emphasizing that each day of delay must be satisfactorily accounted for.

Summary: The appellants, Pepsu Road Transport Corporation and another, sought condonation of 102 days’ delay in filing an appeal against a Motor Accident Claims Tribunal award. They argued that administrative delays and procedural difficulties caused the delay. The Court, however, found no bona fide explanation covering the entire period of delay and noted that such pleas could not override statutory time limits.

Justice Sharma cited Maniben Devraj Shah v. Municipal Corporation of Brihan Mumbai (2012) 5 SCC 157, Lanka Venkateswarlu v. State of Andhra Pradesh (2011) 4 SCC 363, Thirunagalingam v. Lingeswaran (2025 INSC 672), and Shivamma (Dead) by LRs v. Karnataka Housing Board (2025 INSC 1104), reaffirming that liberal or justice-oriented interpretations cannot override the legislative mandate of limitation. The Court observed that the explanation must comprehensively cover the entire duration of delay, and failure to do so renders the appeal non-maintainable.

Decision: The High Court dismissed the application for condonation of delay, holding that no “sufficient cause” was shown to justify the extraordinary delay of 102 days. Consequently, the main appeal (FAO-4562-2025) was also dismissed as time-barred. All pending applications were disposed of accordingly.