Facts: The Petitioner, Nirlon Limited, acquired several land parcels in villages Pahadi and Goregaon through registered indentures in 1962, 1964, and 1965 from Sitaram Narayan Desai. In 2010, the Collector passed an "Area Correction Order" under the Maharashtra Land Revenue Code, 1966, to rectify revenue records, which resulted in a technical gap of 1728.5 sq. mtrs. between the village boundaries. In 2023, Respondent No. 1, the daughter of the original vendor Sitaram, challenged this 2010 order before the Additional Commissioner (Respondent No. 4) after a delay of 13 years, 7 months, and 21 days. Her primary justification for the delay was her attainment of majority in 2003, lack of awareness of the order, and difficulties during the Covid-19 pandemic. Respondent No. 4 condoned this inordinate delay and entertained the appeal.
Procedural Posture: The Petitioner filed a Writ Petition under Article 226 of the Constitution of India before the Bombay High Court challenging the order of the Additional Commissioner that condoned the delay.
Issue: Whether an appellate authority can condone an inordinate delay of over 13 years without recording specific reasons or finding "sufficient cause" as required under Section 5 of the Limitation Act, 1963, and whether heirs of a vendor can claim rights over land sold decades ago due to subsequent technical area corrections.
Holding: No, the condonation of such inordinate delay without a speaking order and without "sufficient cause" is a violation of natural justice and is legally unsustainable.
Reasoning: The Court reasoned that the obligation to record reasons is a mandatory attribute of quasi-judicial power, and a non-speaking order constitutes a breach of the principles of natural justice. Citing "Kranti Associates" and "Balwant Singh", the Court held that while a liberal approach may be taken for minor delays, inordinate delay requires a "sufficient cause" supported by material particulars. Respondent No. 1's claim of being "occupied in management" was deemed a vague assertion that did not demonstrate due diligence. Furthermore, the Court observed that the law of limitation protects crystallized rights; condoning such delay after 13 years, where the Petitioner had already developed the land, would render the Limitation Act otiose. The Court also found the appeal to be filed with "malafide intent" and "ulterior motives" to extract money, constitutes an abuse of the process of the court.