The Law of Limitation must be applied with extreme rigour in consumer matters to prevent indefinite litigation, and internal administrative lapses such as an employee resignation do not constitute 'sufficient cause' to condone a significant, unexplained delay in filing an appeal.

Headnote:(A) Consumer Protection Act, 1986 - Section 15 - Limitation Act, 1963 - Section 5 - Condonation of delay - Appeal filed with delay of 341/354 days - Appellant failed to provide sufficient cause - Law officer leaving job is not a valid ground for condoning such an immense delay - Statutory period of limitation for filing appeal under Consumer law must be strictly adhered to and cannot be extended on equitable grounds.

Facts of the case:
The appellant (Central Bank of India) challenged an order dated 21.02.2025 passed by the District Commission. The appeal was filed with a significant delay of over 300 days. The appellant contended that they were unaware of the order due to a change in personnel (law officer) and that the case should be governed by the Consumer Protection Act, 1986.

Findings of Court:
The Court held that the explanation provided for the delay was insufficient, noting that even from the date the appellant received certified copies, they failed to file the appeal within the limitation period. The Court ruled that the appellant failed to show 'sufficient cause' and that the law of limitation must be applied with all its rigour.

Issues: Whether the delay in filing the appeal deserves to be condoned, and whether the applicant provided 'sufficient cause' as required by law.

Ratio Decidendi: The court observed that rules of limitation are based on public policy. A party cannot claim condonation of delay based on internal administrative negligence like the departure of a law officer without providing specific details or diligent steps taken to rectify the lapse. The court must prioritize strict adherence to statutory timelines in consumer matters.

Result: Appeal dismissed due to delay.

PER: HON’BLE MS. BIMLA KUMARI, MEMBER (FEMALE)

1. The present appeal has been filed on 27.02.2026 (online) and 12.03.2026 (physically) challenging the impugned order dated 21.02.2025 passed in Complaint Case No.41/2020 by the District Consumer Disputes Redressal Commission-X (South-East District) Udyog Sadan, C-22 & 23, Qutub Institutional Area, Behind Qutub Hotel Mehrauli, New Delhi 110016 (hereinafter referred as the District Commission).

2. This order will dispose off an application bearing IA No.647/2026 seeking condonation of delay in filing the appeal, filed along with the appeal. Affidavit of Mrs. Kahkasaha Anjum, Authorized Representative of the appellant has been filed along with this application.

3. I have given considerable thought to the submissions put forth by the learned counsel for the appellant and carefully perused the record.

4. The application has been moved under Section 5 of the Limitation Act, 1963. However, it is being considered under Section 15 of the Consumer Protection Act, 1986 as it is arising out of Complaint Case No.41/2020 (filed on 03.03.2020). Since, before delving into the merits of the present application, it is imperative to ascertain whether the present application bearing IA No. 647/2026 filed along with the appeal on 27.02.2026 (online) and 12.03.2026 (physically) is maintainable under the New Act/Old Act.

5. The repeal of a law shall not affect the previous operation of any enactment i.e. the proceedings under Consumer Protection Act, 1986 shall continue for cases which had been filed prior to the implementation of Consumer Protection Act, 2019 on 20.07.2020. The same can be gauged through the repeal and saving section (Section 107) of the Consumer Protection Act, 2019 which has been reproduced below:

“107. (1) The Consumer Protection Act, 1986 is hereby repealed.

(2) Notwithstanding such repeal, anything done or any action taken or purported to have been done or taken under the Act hereby repealed shall, in so far as it is not inconsistent with the provisions of this Act, be deemed to have been done or taken under the corresponding provisions of this Act.

(3) The mention of particular matters in sub-section (2) shall not be held to prejudice or affect the general application of section 6 of the General Clauses Act, 1897 with regard to the effect of repeal.”

6. We may also take the assistance of Section 6 (b) of the General Clauses Act, 1897 to further this view. Section 6 (b) of the General Clauses Act, 1897 has been reproduced below:

“6 Effect of repeal. : Where this Act, or any 1 [Central Act] or Regulation made after the commencement of this Act, repeals any enactment hitherto made or hereafter to be made, then, unless a different intention appears, the repeal shall not

(a) revive anything not in force or existing at the time at which the repeal takes effect; or

(b) affect the previous operation of any enactment so repealed or anything duly done or suffered thereunder”

7. Moreover, unless the legislature explicitly provides that the amendment is retrospective in nature, it will be considered prospective. The aforesaid view has been taken by the Apex Court in the case of CIT v. Vatika Township (P) Ltd. reported in (2015) 1 SCC 1 wherein the Court discussed the proviso to Section 113 of the Income Tax Act, 1961 and held that it was prospective and not retrospective. While deciding the case, the Constitution Bench laid down certain general principles which have been reproduced as under:

“28. Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation. The idea behind the rule is that a current law should govern current activities. Law passed today cannot apply to the events of the past. If we do something today, we do it keeping in view the law of today and in force and not tomorrow's backward adjustment of it. Our belief in the nature

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2026 Supreme(Online)(SCDRC) 3100

The Law of Limitation must be applied with extreme rigour in consumer matters to prevent indefinite litigation, and internal administrative lapses such as an employee resignation do not constitute 'sufficient cause' to condone a significant, unexplained delay in filing an appeal.

Cases Referred (3)