Court affirms that principles of natural justice must be adhered to, allowing claimants to explain delays in filing claims.
In a landmark decision, the Allahabad High Court has ruled that claimants under the Mukhyamantri Krishak Durghatana Kalyan Yojana should be afforded the opportunity to explain delays in filing claims, reinforcing the principles of natural justice. The Division Bench, comprising Justices Atul Sreedharan and Siddharth Nandan, delivered this judgment while hearing a series of writ petitions, including that of Mala Devi and others, challenging the rejection of their claims due to delayed submissions.
The court scrutinized the Scheme's Clause 10, which mandates a 75-day limitation period for filing claims, and found it to be arbitrary and unreasonable. It held that the doctrine of Wednesbury's reasonableness requires that beneficial schemes, such as this one, which aim to support bereaved farming families, be interpreted liberally. The court emphasized that administrative delays and other factors beyond the control of the applicants could constitute sufficient cause for condonation.
The judgment also examined the applicability of the Limitation Act, 1963, particularly Section 5, to beneficial schemes. It stated that while condonation of delay does not extend the limitation period, it allows for the evaluation of whether the delay was due to factors outside the claimant's control, thereby aligning with Articles 14 and 21 of the Constitution, which uphold the principles of natural justice.
The court further criticized the absence of a provision for appealing or adjudicating rejected claims within the Scheme, asserting that claimants should not be left remedy-less. It directed authorities to permit claimants to file affidavits explaining the delay, which should be considered fairly within a stipulated time frame.
This judgment reaffirms the court's commitment to ensuring that the rights of individuals, especially those from vulnerable sections, are not compromised due to procedural technicalities. It underscores the necessity of a justice-oriented approach over rigid adherence to timelines, ensuring that the Scheme fulfills its intended objective of providing relief to farmers' families.
Bottom Line:
Mukhyamantri Krishak Durghatana Kalyan Yojana - Limitation period for filing claims under the Scheme - Principle of natural justice mandates that claimants should have the opportunity to explain the delay for condonation - Clause 10 of the Scheme does not specifically provide for condonation of delay, but such an opportunity is inherent under Article 14 and 21 of the Constitution.
Statutory provision(s): Articles 14 and 21 of the Constitution of India, Limitation Act, 1963 Section 5, Article 226 of the Constitution of India.
Mala Devi v. State of U.P., (Allahabad)(DB) : Law Finder Doc id # 2877168
