Punjab & Haryana HC: State’s Appeal Dismissed for 992-Day Delay, Court Rejects Excuse of Bureaucratic Lapses
Case Name: The Principal Secretary, Food Civil Supplies and Consumer Affairs Department, Punjab & Ors. v. Varinder Kumar Jain
Date of Judgment: September 25, 2025
Citation: RSA No. 3244 of 2025 (O&M)
Bench: Hon’ble Mrs. Justice Sudeepti Sharma
Held: The High Court dismissed the State’s application for condonation of 992 days’ delay in filing the appeal, reiterating that limitation law is based on public policy and cannot be diluted by habitual bureaucratic lapses or red-tapism. It held that expressions like “liberal approach” and “substantial justice” cannot be stretched to obliterate statutory timelines. The Court relied on Maniben Devraj Shah v. Municipal Corporation of Brihan Mumbai (2012), Lanka Venkateswarlu v. State of Andhra Pradesh (2011), State of M.P. v. Bherulal (2020), and Postmaster General v. Living Media India Ltd. to stress that government departments cannot claim special indulgence. Since the State failed to establish bona fide, sufficient, and cogent cause for the delay, the application was rejected and the appeal dismissed.
Summary: The appellants sought condonation of delay of nearly three years in filing a Regular Second Appeal against a judgment in favour of the respondent. They argued that departmental procedures and administrative red-tapism caused unavoidable delays in arranging documents and approvals. The Court, however, emphasized that modern jurisprudence does not permit treating the State differently from private litigants. Referring to recent Supreme Court pronouncements including Thirunagalingam v. Lingeswaran (2025) and Shivamma v. Karnataka Housing Board (2025), it held that repeated excuses of bureaucratic lethargy and inefficiency amount only to “excuses” and not “explanations.” Courts are duty-bound to scrutinize whether delay reflects genuine diligence or gross negligence. In this case, the explanation was vague, generalized, and failed to account for the entire period of delay. The Court reiterated that public interest is better served by efficiency and timely government action, not by condoning such extraordinary delay.
Decision: The High Court dismissed the application for condonation of delay as devoid of merit and, consequently, dismissed RSA No. 3244 of 2025 itself for being time-barred.