The court emphasized the strict adherence to limitation periods in consumer protection matters, denying condonation of delay due to insufficient justification.

ORDER

This is the Revision Petition filed with a delay of 117 days beyond the 90 days’

period granted for filing Revision Petition before this Commission.

In the Application for condonation of delay, the ground mentioned is that the Petitioner is a Central Government department which requires documents to go through multiple stages of approval and review, which is time consuming. Evidently, such ground cannot be called sufficient cause for condoning the delay.

Being a Consumer Complaint, such condonation would defeat the purpose of the Act. This is a Consumer Complaint matter and has to be decided in a time bound manner and condoning delay beyond a reasonable time without sufficient cause, would go against the letter and spirit of the Consumer Protection Act.

We are relying on the Order of the Hon’ble Supreme Court in Anshul Aggarwal vs. New Okhla Industrial Development Authority , IV (2011) CPJ 63 (SC), wherein, it was held as under:

“It is also apposite to observe that while deciding an application filed in such cases for condonation of delay, the Court has to keep in mind that the special period of limitation has been prescribed under the Consumer Protection Act, 1986 for filing appeals and revisions in consumer matters and the object of expeditious adjudication of the consumer disputes will get defeated if this court was to entertain highly belated petitions filed against the orders of the Consumer Foras."

The Hon’ble Supreme Court in Basavraj & Anr. Vs. The Spl. Land Acquisition Officer, 2013 AIR SCW 6510 observed as under:

"9. Sufficient cause is the cause for which defendant could not be blamed for his absence. The meaning of the word "sufficient" is "adequate" or "enough", inasmuch as may be necessary to answer the purpose intended. Therefore, the word "sufficient" embraces no more than that which provides a platitude, which when the act done suffices to accomplish the purpose intended in the facts and circumstances existing in a case, duly examined from the view point of a reasonable standard of a cautious man. In this context, "sufficient cause" means that the party should not have acted in a negligent manner or there was a want of bona fide on its part in view of the facts and circumstances of a case or it cannot be alleged that the party has "not acted diligently" or "remained inactive". However, the facts and circumstances of each case must afford sufficient ground to enable the Court concerned to exercise discretion for the reason that whenever the Court exercises discretion, it has to be exercised judiciously. The applicant must satisfy the Court that he was prevented by any "sufficient cause" from prosecuting his case, and unless a satisfactory explanation is furnished, the Court should not allow the application for condonation of delay. The court has to examine whether the mistake is bona fide or was merely a device to cover an ulterior purpose. (See: Manindra Land and Building Corporation Ltd. v. Bhootnath Banerjee &Ors., AIR 1964 SC 1336; Lala Matadin v. A.Narayanan, AIR 1970 SC 1953; Parimal v. Veena alias Bharti AIR 2011 SC 1150 (2011 AIR SEW 1233); and Maniben Devraj Shah v.

Municipal Corporation of Brihan Mumbai, AIR 2012 SC 1629: (2012 AIR SCW 2412.)

12. It is a settled legal proposition that law of limitation may harshly affect a particular party but it has to be applied with all its rigour when the statute so prescribes. The Court has no power to extend the period of limitation on equitable grounds. "A result flowing from a statutory provision is never an evil. A Court has no power to ignore that provision to relieve what it considers a distress resulting from its operation. The statutory provision may cause hardship or inconvenience to a particular party but the Court has no choice but to enforce it giving full effect to the same. The legal maxim "dura lex sed lex" which means "the law is hard but it is the law", stands attracted in such a situation. It has consistently been held that, "inconvenience is no