An application for condonation of delay requires a valid, specific explanation for every day of default. Where a litigant remains inactive or negligent, administrative convenience does not constitute 'sufficient cause' to override the statutory period of limitation, particularly in consumer disputes requiring expeditious resolution.

Headnote:(A) Consumer Protection Act, 2019 - Section 41 - Appeal against order of District Commission - Limitation - Condonation of delay of 199 days - Application for condonation of delay found meritless and vague - Requirement to explain every day of delay not satisfied - Conduct of appellant remained inactive and negligent - Limitation law to be applied with rigor as consumer matters require expeditious adjudication - Appeal dismissed as barred by limitation. (Paras 6, 9, 11, 13)

(B) Limitation Act - Condonation of delay - Essential requirement of 'sufficient cause' - Party must not have acted in a negligent manner or remained inactive - Courts cannot condone delay when explanation is inadequate or casual. (Para 10)

Facts of the case:
The appellant entity challenged an order passed by the District Consumer Commission dated 20.06.2025. An application for condonation of delay of 199 days was filed, claiming that administrative and managerial procedures caused the delay. The appellant had previously withdrawn a similar application to file a better one, yet failed to provide a convincing explanation for the extensive period of inactivity.

Findings of Court:
The Court held that the explanation provided for the 199-day delay was vague and devoid of merit. Noting the appellant remained inactive for months, the Court emphasized that statutory limitation periods must be strictly enforced, especially in consumer disputes, to prevent the defeat of the objective of expeditious adjudication. The delay was not considered 'sufficient cause' under the law.

Issues: The main issue was whether the 199-day delay in filing the appeal could be condoned based on the grounds of administrative procedural delays.

Ratio Decidendi: The Court determined that where a party is found to be negligent or fails to exercise due diligence/remains inactive, there is no ground for condonation of delay. Statutory limitation periods must be strictly applied, and a 'casual' approach to filing appeals cannot be rewarded.

Result: Application for condonation of delay dismissed; Appeal dismissed as time-barred.

Table of Content
1. procedural history and the timeline regarding the delay in filing the appeal. (Para 1 , 2 , 3 , 4)
2. strict application of limitation law and the standard for 'sufficient cause'. (Para 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13)
3. dismissal of appeal due to failure to meet limitation criteria and disposal of pending applications. (Para 14 , 15 , 16 , 17)

Appeal under Section 41 of Consumer Protection Act, 2019 to challenge the order dated 20.06.2025 passed in CC No.338 of 2020 by the District Consumer Disputes Redressal Commission, Amritsar.

1) Whether Reporters of the Newspapers may be allowed to see the Judgment?	Yes/No
2) To be referred to the Reporters or not?	Yes/No
3) Whether judgment should be reported in the Digest?	Yes/No

JUSTICE DAYA CHAUDHARY, PRESIDENT:-

The Appellant/OP has filed the present Appeal under Section 41 of the Consumer Protection Act, 2019 (in short the ‘Act’) to challenge the impugned order dated 20.06.2025 passed by the District Consumer Disputes Redressal Commission, Amritsar in CC No.338 of 2020 (in short the “District Commission”) whereby the Complaint had been allowed.

I.A. No.537 of 2026

2. There is delay of 199 days in filing of the present Appeal. I.A. No.537 of 2026 has been filed for condonation of delay of 199 days in filing of the Appeal. Said Application has been supported by an Affidavit.

3. At the time of filing of the Appeal, the Application bearing No.472 of 2026 was filed for condonation of delay. However, on request made by learned Counsel for the Applicant/Appellant, said Application was withdrawn with the liberty to file afresh with better particulars mentioning therein that there were certain inadvertent mistakes in the said Application. Said Application was dismissed as withdrawn with the said liberty. Thereafter, present I.A. No.537 of 2026 has been filed for condonation of delay.

4. Mr. Arjun Grover Advocate, learned Counsel for the Appellant has submitted that the order was passed on 20.06.2025 and it was received by the Appellant on 09.07.2025. Thereafter, the ASM of the respective Branch of the Appellant Company had informed the empaneled Counsel through email dated 12.12.2025 for filing the Appeal and thereafter, the Appeal was drafted and finalized on 15.01.2026. Learned Counsel has further submitted that due to some internal managerial procedures, the demand draft for statutory fee was got prepared by the Head Office of the Appellant Company on 18.02.2026 and thereafter, due to non-availability of renewed power of Attorney of the Authorized Representative of the Appellant Company, the Appeal could not be filed in the month of February, 2026. Further, it has been mentioned that the renewed power of attorney of the authorized representative was received on 10.03.2026 from the Head Office of the Appellant and the Appeal was signed on 10.03.2026 and thereafter it was filed online on 11.03.2026. The delay of 199 days had occurred in filing of the Appeal which is totally procedural and same is not willful nor deliberate but due to said reasons, the time had been consumed in completing the office formalities. Learned Counsel has submitted that the present Application be allowed and delay of 199 days in filing the Appeal be condoned.

5. We have heard the oral arguments raised by learned Counsel for the Applicant/Appellant at preliminary stage. We have also carefully perused the Application for condonation of delay as well as other documents available on record.

6. Admittedly, there is delay of 199 days in filing of the Appeal. Initially, I.A. No.472 of 2026 was filed at the time of filing of the Appeal. Simply, it has been mentioned in the Application that the order dated 20.06.2025 was received by the Appellant on 09.07.2025 and thereafter, on taking necessary approval from the concerned Management, the Counsel was engaged and the Appeal was drafted and thereafter, it was sent for approval/vetting. Further, it has been mentioned that on obtaining necessary

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2026 Supreme(Online)(SCDRC) 2942

STATE CONSUMER DISPUTES REDRESSAL COMMISSIONDaya Chaudhary, President, Simarjot Kaur, MemberLG Electronics India Private Limited – AppellantVersusSanjeev Rai Mehta – RespondentFirst Appeal No.198 of 2026

STATE CONSUMER DISPUTES REDRESSAL COMMISSION
Daya Chaudhary, President, Simarjot Kaur, Member
LG Electronics India Private Limited – Appellant
Versus
Sanjeev Rai Mehta – Respondent
First Appeal No.198 of 2026