Neutral Citation No. 2026:JHHC:17517-DB IN THE HIGH COURT OF JHARKHAND AT RANCHI I.A. No. 13904 of 2024 In L.P.A. No. 72 of 2025 1. The State of Jharkhand through the Secretary, Human Resources Development Department, Government of Jharkhand, Ranchi having office at P.O. & P.S.- Dhurwa, District- Ranchi. 2. The Director Primary Education, Government of Jharkhand, Ranchi having office at P.O. & P.S. - Dhurwa, District - Ranchi. 3. The Deputy Commissioner, Palamu P.O. & P.S.- Medninagar, District : Palamu. 4. The District Superintendent of Education, P.O. & P.S.- Medninagar, District : Palamu. ... Respondents/Appellants Versus Mujjafar Alam, aged about 38 years, son of Late Md. Allaudin, Resident of Gausia Mohalla (Pahari), P.O. & P.S. - Medninagar, District : Palamu (Jharkhand). ... Writ Petitioner/Respondent --------- CORAM: HON’BLE THE CHIEF JUSTICE HON’BLE MR. JUSTICE RAJESH SHANKAR --------- For the Appellants: Mr Ashok Kumar Yadav, Sr SC-I Mr Aditya Kumar, A.C. to Sr. S.C.-I For the Respondent: Mr Binod Kumar, Advocate Ms Nanda Kumari, Advocate --------- Reserved on: 15.06.2026 Pronounced on: 17/06/2026 Per M. S. Sonak, C.J. 1. Heard learned counsel for the parties. 2. This I.A. seeks condonation of the delay of 495 days in filing the appeal against the judgment and order dated 13.07.2023 made by the learned Single Judge, disposing of W.P.(S) No. 346 of 2019. 3. From perusal of the averments in the I.A., no case whatsoever has been made out to explain this inordinate delay. All that the Neutral Citation No. 2026:JHHC:17517-DB application refers to is the routine movement of files and the alleged obtaining of a legal opinion, followed by “thereafter several rounds of discussions were held and after discussion finally the draft of Memo of Appeal was approved for filling of Memo of Appeal against the order dated 13.07.2023 passed in W.P.(S) No. 346 of 2019 and the Memo……”. 4. It is further noted that, in the meantime, a contempt application was filed by the writ petitioner on 25.01.2024 against the appellant-State for non-compliance with the very order dated 13.07.2023. This demonstrates that the appellants were fully aware of the said order and its legal consequences. 5. This circumstance is completely irrelevant to explain the inordinate delay of 495 days. It is, however, highly relevant as it casts serious doubt on the assertion in this application that the delay occurred due to reasons “beyond the control of the appellants”. 6. Furthermore, from a perusal of paragraphs 4 to 11 of the I.A., it is axiomatic that the appellants twice allowed the matter to lie dormant for inexplicably long periods, despite having full knowledge of the impugned order. 7. Firstly, after the file was received by the Under Secretary to examine the legal impact of the order dated 13.07.2023, it was placed before the Joint Secretary only on 22.12.2023, a period of nearly five months left completely unexplained. Secondly, after the grounds of appeal were sent to the Law Department on 16.04.2024, the file was Neutral Citation No. 2026:JHHC:17517-DB placed before the Regional Education Officer only on 23.10.2024, resulting in a further delay of over six months. Evidently, for a cumulative period of nearly eleven months out of the total 495 days, the appellants took no steps whatsoever in furtherance of the matter. 8. In such circumstances, it is well settled that an application filed with utmost casualness, and founded upon routine bureaucratic delays, cannot be accepted as showing any sufficient cause. 9. Learned counsel for the appellants attempts to argue that the State has a good case on the merits. However, there is nothing on record to show that a prima facie case exists. Be that as it may, merely having a good case on merits cannot be the sole consideration for condoning a delay of 495 days when no sufficient cause is shown. 10. In this regard, reliance can be placed on the dictum of the Hon’ble Supreme Court in Postmaster General and Others v. Living Media India Limited and Another, reported in (2012) 3 SCC 563. In the said case, the Hon’ble Court held that Government departments staffed with legally conversant personnel cannot claim any special or extended period of limitation. Mere recitation of dates of file movement, without explaining the reason for each interval, does not constitute sufficient cause. The Court categorically rejected the excuse of impersonal machinery and bureaucratic methodology, particularly in the age of modern technology, and held that delay cannot be condoned mechanically solely because the applicant is the Government or a wing thereof. Neutral Citation No. 2026:JHHC:17517-DB 11. Moreover, in the recent past, the Hon’ble Supreme Court in the case of Union of India & Anr. vs. Jahangir Byramji Jeejeebhoy (D) through his LR, reported in 2024 SCC OnLine SC 489, held that the status of a litigant, whether private or State, is immaterial when condoning gross delay. Prolonged inaction cannot be presumed non-deliberate, and in such circumstances, a plea of substantial justice cannot override the bar of limitation. The Hon’ble Court further held that before adverting to the merits, the court must first assess the bona fides of the explanation offered; merits may be taken into aid only where the explanation and the opposition are evenly balanced. Reiterating that limitation is grounded in public policy and equity, the Hon’ble Court held that delay cannot be excused as a matter of generosity. 12. The Hon’ble Supreme Court has held that the rules of limitation are based on the principles of sound public policy and equity. The length of the delay is a relevant consideration in the condonation of delay in filing an appeal. If it is found that the delay in filing the appeal has arisen due to the party's own negligence and casual attitude, the delay may not be condoned on the grounds of doing substantial justice. 13. The Hon’ble Supreme Court has also held that it is trite law that a government department cannot claim a separate period of limitation. The law of limitation undoubtedly binds everyone, including the Government. The claim for condonation of delay on account of Neutral Citation No. 2026:JHHC:17517-DB impersonal machinery and the inherited bureaucratic methodology of making several notes cannot be accepted in view of the modern technologies available and in use. If it is found from the record of a particular case that the department(s) or the officials concerned were not diligent in prosecuting the matter in the Court by taking appropriate steps, the application for condonation of delay is liable to be rejected. 14. In Shivamma (Dead) by Lrs. Vs. Karnataka Housing Board & Ors., 2025 SCC OnLine SC 1969, the Hon’ble Supreme Court has once again made it abundantly clear that “administrative lethargy and laxity” can never stand as a sufficient ground for condonation of delay. The Hon’ble Supreme Court in para 261 observed “we want to convey an emphatic message to all the High Courts that delays shall not be condoned on frivolous and superficial grounds, until a proper case of sufficient cause is made out, wherein the State-machinery is able to establish that it acted with bona fides and remained vigilant all throughout. Procedure is a handmaid to justice, as is famously said. But courts, and more particularly the constitutional courts, ought not to obviate the procedure for a litigating State agency, who also equally suffer the bars of limitation from pursuing litigations due to its own lackadaisical attitude.” 15. The Hon’ble Supreme Court further observed that the High Courts ought not give a legitimising effect to such callous attitude of the State authorities or their instrumentalities, and should remain extra Neutral Citation No. 2026:JHHC:17517-DB cautious if the party seeking condonation of delay is a State authority. They should not become surrogates for State laxity and lethargy. The constitutional courts ought to be cognizant of the apathy and pangs of a private litigant. Litigants cannot be placed in situations of perpetual litigation, wherein the fruits of their decrees or favourable orders are frustrated at later stages. 16. The Hon’ble Supreme Court observed: “We are at pains to reiterate this everlasting trend, and put all the High Courts to notice, not to reopen matters with inordinate delay, until sufficient cause exists, as by doing so the courts only add insult to the injury, more particularly in appeals under Section 100 of the CPC, wherein its jurisdiction is already limited to questions of law”. 17. The Hon’ble Supreme Court has further observed that limitation periods are prescribed to maintain a sweeping scope for the lis to attain for finality. More than the importance of judicial time, what worries is the plight of a litigant with limited means, who is to contest against an enormous State, and its elaborate and never exhausting paraphernalia. 18. The Hon’ble Supreme Court has further observed that such litigations deserve to be disposed of at the very threshold, because, say, if a party litigating against the State, for whatever reason, is unable to contest the condonation of delay in appeal, unlike the present case, it reopens the lis for another round of litigation, and leaves such litigant listless yet again. As courts of conscience, Neutral Citation No. 2026:JHHC:17517-DB Courts are obligated to ensure that a litigant is not sent from pillar to post to seek justice. No litigant should be permitted to be so lethargic and apathetic, much less be permitted by the courts to misuse the process of law. 19. Applying the above principle to the gross facts and circumstances of the present case, we are satisfied that no sufficient cause has been shown and consequently, we dismiss this I.A., seeking condonation of delay of 495 days in filing the accompanying appeal. 20. As a consequence, the accompanying appeal and the I.A. therein, do not survive and are disposed of. (M. S. Sonak, C.J.) (Rajesh Shankar, J.) June 17, 2026 N.A.F.R. Manoj/Cp.2 Uploaded on 17.06.2026