Neutral Citation No. 2026:JHHC:22040-DB IN THE HIGH COURT OF JHARKHAND AT RANCHI I.A. No. 7580 of 2025 In / And L.P.A. No. 322 of 2025 Guddu Lal, S/O Late Harilal Khatik, aged about – 43 years, R/o Village Kedla Nagar, P.O. Kedla, P.S. Mandu, District - Hazaribagh … Petitioner/Appellant Versus 1. The Central Coalfield Limited, through its Chairman Cum Managing Director, having its office at Darbhanga House, P.O. Darbhanga House, P.S. Kotwali, District – Ranchi. 2. Director General, C.C.L. Darbhanga House, P.O. Darbhanga House, P.S. Kotwali, District Ranchi. 3. General Manager (P&IR), C.C.L., Darbhanga House, P.O. & P.S. Kotwali, District – Ranchi. 4. General Manager, Charhi Area, P.O. & P.S., Charhi, District Hazaribag. 5. Project Officer, C.C.L. Kedla Project, P.O. & P.S., Kedla, District – Hazaribag. … Respondents/Respondents --------- CORAM: HON’BLE THE CHIEF JUSTICE HON’BLE MR. JUSTICE RAJESH SHANKAR --------- For the Appellants: Mr. Manoj Kumar Sinha, Advocate Mr Abhishek Kumar, Advocate Mr Uday Prakash, Advocate For the Respondents: Mr. Amit Kumar Das, Senior Advocate Ms Swati Shalini, Advocate --------- 06/Dated: 22.07.2026 1. Heard learned counsel for the parties. 2. This I.A. seeks condonation of the delay of 800 days in filing the appeal against the judgment dated 07.11.2022 made by the learned Single Judge disposing of W.P. (S) No. 3952 of 2017. Neutral Citation No. 2026:JHHC:22040-DB 3. The sole ground urged in support of the application is that the appellant was suffering from a serious medical condition. According to him, he remained under continuous medical supervision from 25.11.2022 to 10.12.2024 owing to severe back pain; therefore, his movements were substantially restricted. It is further stated that only thereafter could he apply for a certified copy of the impugned judgment on 22.10.2024, which was made available on 14.11.2024, and eventually institute the present appeal on 14.02.2025. In support of these assertions, the appellant has placed on record the relevant medical documents, which have been carefully examined by this Court. 4. A scrutiny of the medical records would reveal that the appellant was admitted to the hospital on 25.11.2022 and discharged on 29.11.2022. The records further disclose that he was diagnosed with “Infective Spondylodiscitis”. At the same time, the subsequent medical reports unmistakably indicate that his physical condition progressively improved over the following months. 5. The medical documents further reveal that the appellant was advised complete bed rest for a period of two months on 22.12.2022. Significantly, however, no subsequent medical record discloses any further advice requiring prolonged bed rest. On the contrary, the appellant was advised to undergo physiotherapy, wear an L.S. Belt and continue with regular medication. The nature Neutral Citation No. 2026:JHHC:22040-DB of these directions, viewed cumulatively, reflects that the course of treatment thereafter was primarily rehabilitative rather than one necessitating complete physical immobility. 6. At this stage, it is apposite to advert to the stand taken by the respondents. Relying upon the endorsement “patient better” recorded by the treating doctor on 24.07.2023, the respondents contend that the appellant had substantially recovered by the said date and, therefore, his assertion that he remained incapacitated throughout the period from 25.11.2022 to 10.12.2024 cannot be accepted. 7. Upon a meticulous perusal of the entire medical record, this Court finds considerable merit in the aforesaid submission. Most importantly, after 24.07.2023, the medical records contain no adverse observations indicating deterioration in the appellant's condition. That said, this Court is mindful of the nature and symptoms of Infective Spondylodiscitis. Equally, however, it cannot overlook the repeated observations of the treating doctor dated 21.03.2023, 23.08.2023, 03.01.2024, 05.05.2024 and 10.12.2024, all of which demonstrate a gradual and sustained improvement in the appellant's condition. In the absence of any medical opinion indicating continued incapacity, it would be wholly untenable to infer that the disease was of such severity as to Neutral Citation No. 2026:JHHC:22040-DB completely disable the appellant from approaching this Court for the entire period in question. 8. Moreover, the appellant’s own pleadings further belie his case. In paragraph 8 of the I.A., he states that he was undergoing treatment at home by way of massages and minor exercises. This assertion, far from establishing complete incapacity, reinforces the medical record indicating that his condition had substantially improved. Consequently, after 24.07.2023, no credible or compelling circumstance has been shown which prevented the appellant from availing of his legal remedy within a reasonable time. 9. In paragraph 9 of the I.A., the appellant states that he came to know of the dismissal of the writ petition only after being informed by the office of his conducting counsel and that he thereafter requested one of his colleagues to pursue the matter and obtain a certified copy of the judgment. This explanation raises more questions than it answers. Once the appellant was in a position to request a colleague to pursue the matter on his behalf, there is no explanation whatsoever as to why similar steps could not have been taken at any earlier point of time. Merely stating that the dismissal order was communicated to him belatedly by his counsel cannot absolve him of his obligation to remain vigilant and diligently pursue the remedy available in law. Neutral Citation No. 2026:JHHC:22040-DB 10. That apart, even assuming the aforesaid explanation to be correct, it fails to account for the further delay that ensued after the certified copy of the judgment was obtained on 14.11.2024. The present appeal came to be instituted only on 14.02.2025, nearly three months thereafter. The I.A. is conspicuously silent as to what prevented the appellant from filing the appeal during this period. Thus, even the subsequent delay remains wholly unexplained, leaving a conspicuous break in the chronology sought to be projected by the appellant. 11. The inevitable conclusion, therefore, is that the present application fails to disclose any sufficient or plausible cause warranting condonation of the extraordinary delay of 800 days. While the medical records may explain the appellant's inability for a limited duration, they do not justify the continued inaction after 24.07.2023. The delay thereafter is attributable not to any genuine medical incapacity but to the appellant’s own lack of diligence, indifference and inaction. 12. Furthermore, the law in this regard is well-settled. The Hon’ble Supreme Court in the case of Basawaraj & Anr. V. Special Land Acquisition Officer, reported in (2013) 14 SCC 81 has categorically defined the phrase “sufficient cause” as an adequate reason for a party's absence or delay for which they cannot be held blameworthy, evaluated from the perspective of a reasonable and Neutral Citation No. 2026:JHHC:22040-DB cautious person. To qualify, the party must demonstrate that they did not act negligently, remain inactive, or lack good faith. Courts must exercise judicious discretion based on the specific facts of each case to determine if the applicant has provided a satisfactory explanation for being prevented from prosecuting their case. Ultimately, the court must be convinced that the party's error or delay was genuine and not a deceptive device used to conceal an ulterior purpose before allowing an application for condonation of delay. 13. Additionally, the Hon’ble Apex Court in the case of Brijesh Kumar v. State of Haryana, reported in (2014) 11 SCC 351, has also held that an extension of the prescribed legal time limit can only be granted if a "sufficient cause" for the delay is satisfactorily and convincingly explained to the court. The Hon’ble Court emphasised that an inordinate delay stemming from negligence, inaction, or a lack of good faith (bona fides) automatically disentitles a claimant from this legal protection. 14. In this regard, reliance can also further be placed on the recent dictum of the Hon’ble SC, in the case of Union of India & Anr. vs. Jahangir Byramji Jeejeebhoy (D) through his LR, reported in 2024 SCC OnLine SC 489, wherein the Hon’ble Court held that the status of a litigant, whether private or State, is immaterial when condoning gross delay. Prolonged inaction cannot be Neutral Citation No. 2026:JHHC:22040-DB 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. 15. The Hon’ble Supreme Court has, time and again, 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 condoning 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. 16. In Esha Bhattacharjee v. Mng. Committee Civil Appeal No. 8183- 8184 of 2013, the Hon’ble Supreme Court has held that there is a distinction between inordinate delay and a delay of a short duration or a few days, for to the former doctrine of prejudice is attracted whereas to the latter it may not be attracted. That apart, the former warrants a strict approach whereas the latter calls for a liberal delineation. Neutral Citation No. 2026:JHHC:22040-DB 17. Applying the above principles 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 the delay of 800 days in filing the accompanying appeal. 18. As a consequence, the accompanying appeal and the I.A. therein do not survive and are disposed of. No costs. (M. S. Sonak, C.J.) (Rajesh Shankar, J.) July 22, 2026 N.A.F.R. Manoj/ Cp.2 Uploaded on 27.07.2026