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2025 Supreme(SC) 519

SUDHANSHU DHULIA, AHSANUDDIN AMANULLAH
Inder Singh – Appellant
Versus
State Of Madhya Pradesh – Respondent


Advocates appeared:
For the Petitioner(s): Mr. Arjun Garg, AOR Ms. Kriti Gupta, Adv. Ms. Sagun Srivastava, Adv. Mr. Saaransh Shukla, Adv.
For the Respondent(s): Mr. Sarad Kumar Singhania, AOR Mr. Sarthak Raizada Ga, Adv. Ms. Rashmi Singhania, Adv.

Judgement Key Points

Certainly. Based on the provided legal document, the key points are as follows:

  1. The Court emphasized that the State cannot be given undue indulgence regarding limitations; all parties, including the State, are required to act with due diligence and promptitude in legal proceedings (!) .

  2. While delay cannot be condoned without sufficient cause, the Court highlighted that if the merits of a case need to be examined, proceedings should not be dismissed solely on the basis of limitation. The focus should be on the substantive issues rather than procedural delays (!) .

  3. The Court acknowledged that delays, especially in cases involving public land claims by the State, may be excusable if explained properly, particularly when the delays are caused by procedural hurdles or extraordinary circumstances such as the COVID-19 pandemic (!) .

  4. The Court clarified that the exercise of discretion to condone delay is discretionary and should consider factors like negligence, want of due diligence, and inordinate delay. A liberal approach may be adopted when plausible causes for delay are shown, but this does not mean limitation should be waived outright (!) (!) .

  5. The Court stressed that substantial justice is paramount and that delays should be viewed in the context of the overall circumstances, including the importance of the land in question and the conduct of the parties involved. When the matter involves land claimed by the State and in its possession, the case merits a thorough examination on its merits rather than dismissal on technical grounds (!) .

  6. The Court observed that procedural delays, especially those involving government entities, should be approached with caution, ensuring that due diligence is exercised, and delays are not due to negligence or lack of promptness (!) (!) .

  7. The Court upheld the order to condone the delay in filing the Second Appeal on the condition that the respondent pays costs to the appellant. This approach aims to balance procedural fairness with substantive justice, recognizing the importance of the land dispute and the need for a fair hearing (!) .

  8. The Court dismissed the appeal but directed that, upon payment of costs, the Second Appeal should be taken up on priority and disposed of expeditiously. The Court also noted that its observations are limited to the context of the order under consideration and do not influence the merits of the case on appeal (!) (!) .

Please let me know if you need a detailed analysis or assistance with specific legal questions related to this case.


JUDGMENT : 

AHSANUDDIN AMANULLAH, J.

Leave granted.

2. This appeal is directed against the Order dated 29.01.2024 (hereinafter referred to as the ‘Impugned Order’) passed by a learned Single Bench of the High Court of Madhya Pradesh, Gwalior Bench (hereinafter referred to as the ‘High Court’) in I.A. No.2022/2020 in Second Appeal No.1253 of 2020 filed by the respondent, whereby the said I.A. under Section 51[‘5. Extension of prescribed period in certain cases.—Any appeal or any application, other than an application under any of the provisions of Order XXI of the Code of Civil Procedure, 1908 (5 of 1908), may be admitted after the prescribed period if the appellant or the applicant satisfies the court that he had sufficient cause for not preferring the appeal or making the application within such period. Explanation.—The fact that the appellant or the applicant was misled by any order, practice or judgment of the High Court in ascertaining or computing the prescribed period may be sufficient cause within the meaning of this section.’] of the Limitation Act, 1963, seeking condonation of delay in filing the Second Appeal, has been allowed with a direction for listing the Second Appeal t

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