Strict adherence to limitation periods under the Consumer Protection Act is essential; unreasonable delays cannot be condoned without adequate justification.

ORDER

1. These Second Appeals against the concurrent findings given by the learned District Consumer Disputes Redressal Commission, Betul, Madhya Pradesh and the learned Madhya Pradesh State Consumer Disputes Redressal Commission, Bhopal, have been filed by the appellant/respondent no.2 under Section 51 (2) of the Consumer Protection Act , 2019 (for short the Act) against the judgment/order dated 27.08.2024 passed by the learned State Consumer Disputes Redressal Commission (for short the State Commission) , Madhya Pradesh, Bhopal in Appeal Nos. 1855 of 2023, 1727 of 2023, 1857 of 2023, 997 of 2024, 1729 of 2023, 1858 of 2023, 2859 of 2023, 1730 of 2023, 1728 of 2023 and 1856 of 2023 respectively. These second appeals have been filed with a delay of 158 days, 167 days, 180 days, 178 days, 184 days, 184 days, 190 days, 189 days, 199 days and 198 days respectively.

2. For condonation of the said delay IA/3752/2025, IA/3757/2025, IA/4456/2025, IA/4464/2025, IA/4535/2025, IA/4549/2025, IA/4857/2025, IA/5098/2025, IA/5102/2025 AND IA/5116/2025 respectively have been moved.

3. Heard the learned counsel for the appellants on the delay

4. Learned counsel for the appellant submitted that the delay was caused for the reason that the certified copy of the impugned order dated 27.08.2024, passed by the learned State Commission was received on 04.09.2024. Thereafter, it took some time for the appellant to procure approval from the higher authorities to challenge the said order. It has further been argued that in the month of October, 2024, the appellant contacted its local counsel in Bhopal to procure all the relevant documents and with much deliberation by November, 2024; the appellant could receive all the relevant documents from the local counsel. It has further been submitted that after receiving the documents, the appellant contacted the present counsel for filing the revision petition. Most of the documents were in Hindi Language so the translation was to be done and it took some more time.

5. It has further been submitted that due to pronouncement of a Judgment recently in Vivo Mobile India Private Limited Vs. Smt. Mavuram Sujatha in RP No. 1879 of 2024 dated 20.01.2025, the appellant has to file the second appeal, where the time limit is only of thirty days. Previously revision petition was being filed where the limitation period was ninety days so in that situation, the delay was caused.

6. Considered the submissions made by the learned counsel regarding the delay caused. The submissions made are not convincing as the appellant is a company having sufficient wherewithal. Even if it is taken into account that the time limit for filing the revision is ninety days before the pronouncement of the Judgment of Vivo Mobile India (supra), even then there is considerable delay, varying from 98 days to 139 days in filing.

7. Being a Consumer dispute, such condonation would defeat the purpose of the Act. This is a Consumer Complaint related 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 .

8. We are relying on the Order of the Hon’ble Supreme Court in Anshul Aggarwal vs. New Okhla Industrial Development Authority , (2011) 14 SCC 578, 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 expeditiou