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2026 Supreme(Online)(SCDRC) 12155

STATE CONSUMER DISPUTES REDRESSAL COMMISSION
Padma Pandey, Presiding Member, Rajesh K. Arya, Member
ICICI Lombard General Insurance Company Limited – Appellant
Versus
Inderjit Kaur – Respondent
IA/204/2026 | Appeal No. 79 of 2026



Important Points

Condonation of delay requires a substantiated 'sufficient cause' and proof of due diligence; vague assertions of internal administrative delays are insufficient to override the statutory mandate of limitation, especially under the Consumer Protection Act.

Subject

Civil - Consumer Protection

Act Referred

Headnote

(A) Condonation of Delay - Sufficient Cause - Vague explanations regarding internal administrative procedures and routing of files between local and head offices do not constitute 'sufficient cause' for condoning a delay of 112 days. (Para 4)

(B) Law of Limitation - Due Diligence - The applicant is under a legal obligation to furnish a reasonable, satisfactory, and convincing explanation covering the entire period of delay; delay attributable to negligence, inaction, or internal administrative indifference cannot be condoned as a matter of right. (Para 3, 4)

(C) Consumer Protection Act - Expeditious Adjudication - Special periods of limitation prescribed under the Act are intended to secure speedy justice and cannot be liberally extended to the detriment of the object of the statute. (Para 5, 6)

Issues: Whether the delay of 112 days in filing the appeal could be condoned on the ground of long-drawn internal administrative procedures.

Legal Category Hierarchy

  • practice and procedure
    • limitation
      • condonation of delay
        • sufficient cause
    • appeal
      • time-barred appeal
  • consumer law
    • consumer protection act
      • expeditious adjudication

Advocates:
For the Appellants/Petitioners: Rajneesh Malhotra
For the Respondents: Aman Sharma

PER PADMA PANDEY, PRESIDING MEMBER

The instant appeal has been filed by the opposite parties – Lombard General Insurance Company Limited (appellants herein) against order dated 09.10.2025 passed by the District Consumer Disputes Redressal Commission-II, U.T., Chandigarh (in short ‘District Commission’) vide which consumer complaint bearing No.702 of 2020 filed by the complainants (respondents herein) has been partly allowed. However, there is a delay of 112 days in filing the appeal, for condonation whereof, the appellants have also moved IA/204/2026. The sole ground urged in the application for condonation of delay is that the copy of order dated 09.10.2025 was sent to the local office and further to the Head Office for taking a decision regarding filing of the appeal. Thereafter, after going through the record of the case, the competent authority decided to file an appeal and Counsel was engaged. The case file was sent to the Counsel and the appeal was prepared and filed. It has been stated that the delay in filing the appeal is due to long drawn procedure and not intentional on the part of the appellants.

2] The respondents/complainants contested the application for condonation of delay by filing their reply wherein they stated that the delay has not been substantiated with proof and evidence, which amounts to illegal approach. It has further been stated that the application is bereft of any material, particulars, bona fide explanations or ‘sufficient cause’ as mandated under the statute. It has further been stated that the expression “sufficient cause” cannot be interpreted liberally to rescue a negligent or indolent litigant who sleeps over their rights. In support of their submissions, the respondents have relied upon Anshul Aggarwal v. New Okhla Industrial Development Authority , (2011) 14 SCC 578; State Bank of India v. M. B. Krishnan , (2018) 7 SCC 313 and Basawaraj & Anr. v. The Spl. Land Acquisition Officer, (2013) 14 SCC 81. Lastly prayer for dismissal of the application for condonation of delay and consequently, the appeal also being time barred has been made.

3] After giving our thoughtful consideration to the rival submissions of the Learned Counsel for the parties, perusing the ground raised in the application for condonation of delay, its reply filed by the respondents and going through the material available on record, we are of the considered view that the ground taken by the appellants for seeking condonation of an inordinate delay in filing the appeal do not constitute “sufficient cause” within the meaning of law. It is well settled that while considering an application for condonation of delay, the applicant is under a legal obligation to furnish a reasonable, satisfactory and convincing explanation covering the entire period of delay. The expression ‘sufficient cause’ cannot be construed so liberally as to render the statutory period of limitation otiose. Although a liberal approach may be adopted where the explanation is bona fide and free from negligence or inaction, such discretion cannot be exercised in favour of a litigant who has failed to act with due diligence or whose conduct reflects negligence, casualness or lack of bona fides.

4] In the present case, the explanation furnished by the appellants that the delay in filing the appeal occurred due to long drawn procedure is wholly vague, evasive and unsupported by any cogent material. The appellants have neither disclosed the date on which the certified copy of order dated 09.10.2025 was received by them; dates and time consumed at each stage, names/designations of the persons/authorities concerned or any material demonstrating that despite exercising due diligence, they were prevented from filing the appeal within the prescribed period. It is equally well settled that a litigant cannot claim condonation as a matter of right merely by describing the delay as bona fide or unintentional; the applicant must establish a real and sufficient cause which

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