Supreme Court Overturns Madhya Pradesh High Court's Delay Condonation in Civil Appeal

Apex Court Remands Case for Fresh Consideration, Citing Lack of Proper Cause Assessment

In a significant ruling, the Supreme Court of India has set aside an order by the Madhya Pradesh High Court which had previously condoned a delay of 1612 days in filing a civil appeal. The case, titled "Shankargir v. State of MP," was reviewed by a bench consisting of Justices J.B. Pardiwala and Prasanna B. Varale, who found that the High Court had allowed the delay without adequately assessing the sufficiency of the cause presented by the State.

The appeal arose after the appellant, Shankargir, challenged the High Court's decision to condone the substantial delay without a detailed inquiry into the reasons presented. The High Court had granted the delay condonation on September 1, 2025, based on I.A. No.6849/2024, but the Supreme Court observed a lack of justification in the impugned order.

During the proceedings, Ms. Aishwarya Bhati, representing the State, argued that the delay was due to disruptions caused by the Covid-19 pandemic. However, the Supreme Court noted that the High Court's order did not mention this reasoning, nor did it provide any substantial discussion on the cause of delay.

Justice Pardiwala, highlighting past Supreme Court decisions, stressed the importance of properly assessing the 'sufficient cause' for delay as stipulated under the Limitation Act, 1963. The bench referred to previous judgments, including "Union of India v. Jahangir Byramji Jeejeebhoy" and "Shivamma v. Karnataka Housing Board," underscoring the settled legal position on delay condonation.

The Supreme Court's decision remands the matter back to the Madhya Pradesh High Court, instructing it to conduct a fresh hearing and issue a new order in alignment with legal standards. The apex court emphasized the necessity for the High Court to hear the parties involved and consider the delay application thoroughly.

This judgment reinforces the judiciary's commitment to maintaining procedural integrity and ensuring that delay condonations are granted only after a meticulous evaluation of the reasons provided. The case will now return to the High Court for further proceedings, where the parties will have another opportunity to present their arguments regarding the delay.

Bottom Line:

Delay condonation - High Court condoned delay of 1612 days without proper assessment of sufficient cause - Supreme Court set aside the impugned order and remanded the matter for fresh consideration.

Statutory provision(s): Limitation Act, 1963

Shankargir v. State of MP, (SC) : Law Finder Doc Id # 2821752