A delay in filing a revision petition under the Consumer Protection Act can only be condoned upon proving 'sufficient cause' through cogent, day-to-day explanations; routine reasons like professional commitments or document translation do not constitute sufficient cause to override the statutory mandate for expeditious adjudication.

BEFORE:

HON’BLE AVM JONNALAGADDA RAJENDRA, AVSM VSM (Retd.), PRESIDING MEMBER

For the Petitioner (s) : Mr. Ankit Sahu, Advocate

Dated : 25.03.2026

ORDER (ORAL)

1. As per the record of the Registry, there is a delay of 465 days in filing this Revision Petition. Accordingly, IA No. 3160 of 2026 has been filed by the Petitioner seeking condonation of delay. In the said IA, the Petitioner contended that this Revision Petition has been delayed since the certified copy of the impugned Order dated 25.04.2024 was applied for on the same day and was received only on 10.05.2024. Despite best efforts, the Appeal could not be filed within the prescribed limitation period due to bona fide reasons. It was further contended that the Appellant is a practising medical professional permanently residing and practising in Tirunelveli, Tamil Nadu, whereas the NCDRC is situated in New Delhi. Owing to the considerable geographical distance, there was an inevitable delay in obtaining and forwarding the certified copy of the impugned order along with the voluminous case records to the counsel engaged at New Delhi. The records had to be compiled, sorted and dispatched through post/courier for legal scrutiny, which consumed substantial time. On preliminary scrutiny, he was advised to procure additional supporting documents and clarificatory statements regarding the treatment of the complainant/patient, both prior and subsequent to the alleged incident. The delay thus occurred in the bona fide process of preparing a comprehensive and complete record for adjudication before this Commission. A substantial portion of the original treatment records, medical notes, and hospital correspondence was in the Tamil. For the purpose of effective adjudication before this Commission, such records were required to be translated into English and attested to maintain their evidentiary value. The process of identifying a qualified translator, translating technical medical documents accurately, and verifying the same consumed considerable time. This exercise was indispensable for the fair and complete presentation of the case and was undertaken in good faith, without any intention to delay the proceedings. The Appellant, being a qualified and practising medical professional, was unable to devote continuous attention to the preparation of the Appeal within the limitation period without disrupting ongoing medical responsibilities. The delay in filing the present Appeal is thus a consequence of Appellant’s bona fide discharge of essential professional duties, constituting sufficient cause under law. The Appeal is neither deliberate nor attributable to negligence or indifference, but has occurred due to bona fide practical difficulties and circumstances beyond his control. The Appellant has acted in good faith and with due diligence in pursuing a legitimate and meritorious remedy before this Hon’ble Commission.

2. As regards period of limitation for filing of a Revision Petition, Regulation 14 of the CP (Consumer Commission Procedure) Regulations, 2020 inter alia stipulates that:-

"Subject to the provisions of sections 40, 41, 50, 51, 60, 67 and 69, the period of limitation in the following matters shall be as follows:-

i) Revision Petition shall be filed within ninety days from the date of receipt of certified copy of the order..."

3. In this Revision Petition, the learned State Commission passed the Impugned Order on 25.04.2024. The limitation for filing the Revision Petition before this Commission is 90 days. However, the period of limitation for filing the Revision Petition would commence from the date