The Supreme Court of India recently reiterated the importance of adopting a liberal approach in condoning delays, particularly when rejecting an appeal solely on limitation grounds would obstruct substantial justice. The Court clarified that while delays cannot be excused without sufficient reason, a case's merits should not be dismissed on technical grounds alone.
Background of the Case
The matter arose from a dispute regarding land ownership between a private individual, Inder Singh, and the State of Madhya Pradesh. The land in question was categorized as government-owned grazing land, allocated for public purposes.
Inder Singh had initially filed a civil suit seeking ownership rights over the land, which the trial court dismissed. However, the First Appellate Court ruled in his favor, declaring him the rightful owner. The State then sought a review of this decision, which was dismissed due to excessive delay. Subsequently, the State filed a Second Appeal along with an application to condone the 1537-day delay.
Read Also:- Supreme Court Reaffirms Consumer's Right to Approach Forum Despite Arbitration Clause
Despite the significant delay, the High Court allowed the Second Appeal, reasoning that the dispute involved government land meant for public use. The court emphasized that rejecting the appeal solely due to a procedural lapse would be unjust.
Challenging the High Court's decision, Inder Singh appealed to the Supreme Court. The Supreme Court, upholding the High Court’s ruling, stressed that justice must not be compromised by procedural technicalities.
“There can be no quarrel on the settled principle of law that delay cannot be condoned without sufficient cause, but a major aspect which has to be kept in mind is that, if in a particular case, the merits have to be examined, it should not be scuttled merely on the basis of limitation.”
The Court highlighted past precedents that advocate a balanced approach when considering delay condonation applications, particularly when a dispute involves public interest.
Ramchandra Shankar Deodhar v. State of Maharashtra (1974) – The Court held that substantial justice must prevail over procedural delays.
Sheo Raj Singh v. Union of India (2023) – Emphasized a liberal approach in condoning delays, particularly when the State is involved in litigation.
Read Also:- Justice Yashwant Varma Transferred to Allahabad HC Amid In-House Inquiry Over Cash Controversy
State of Bihar v. Kameshwar Prasad Singh (2000) – Reinforced that procedural technicalities should not obstruct the dispensation of justice.
After reviewing the facts and legal precedents, the Supreme Court ruled that the delay in filing the Second Appeal should be condoned. However, it warned that the State must act with greater diligence in future cases.
“In the peculiar facts and circumstances of the case, which relate to land claimed by the State as government land and in its possession, we are persuaded not to interfere with the Impugned Order.”
Accordingly, the appeal was dismissed.
Case Title: INDER SINGH VERSUS THE STATE OF MADHYA PRADESH
Appearances:
For Petitioner(s) Mr. Arjun Garg, AOR
For Respondent(s) Mr. Amit Sharma, A.A.G. Mr. Sarad Kumar Singhania, AOR Mr. Kshitiz Singh, Adv.
