State of U.P. and Another v. Mohan Lal, 2025
It highlights that condonation of delay is an exceptional remedy, and negligence or casual procedural delay by government cannot justify it.
Judgement Details
Court
Allahabad High Court
Date of Decision
26 December 2025
Judges
Justice Neeraj Tiwari and Justice Vivek Kumar Singh
Citation
Acts / Provisions
Facts of the Case
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The State of U.P. filed a review petition after a delay of 5,743 days in a case under the Urban Land (Ceiling and Regulation) Repeal Act, 1999, originally decided on 13 November 2009.
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The State explained part of the delay by stating an SLP had been filed before the Supreme Court, which was dismissed on 03 May 2024 (after a delay of 1,633 days) both on merits and delay.
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From the date of the Supreme Court order, there was an additional 489-day delay in filing the review petition before the High Court.
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The State attempted to justify the delay through bureaucratic processes: sending proposals to the State Government, communication with lawyers, obtaining records from advocates, and other procedural mechanisms.
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No sufficient cause for the extensive delay was demonstrated.
Issues
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Whether the State can seek condonation of delay of 5,743 days in filing a review petition?
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Whether government agencies should be treated differently from private litigants when explaining delay?
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Whether negligence or casual inaction by the State can constitute sufficient cause for condonation of delay?
Judgement
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The High Court held that government departments have a special obligation to act with diligence and commitment, including filing petitions on time.
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The Court emphasized that the law treats all parties equally, and condonation of delay is an exception, not a routine benefit for government agencies.
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Reliance on bureaucratic delays, procedural steps, or internal communications does not constitute sufficient cause for such an extraordinary delay.
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The High Court referred to precedents including Union of India v. Central Tibetan Schools Admin & Ors., Madhya Pradesh and others v. Bherulal, Union of India v. Jahangir Byramji Jeejeebhoy, and Majji Sannemma v. Reddy Sridevi to clarify that “sufficient cause” cannot be applied liberally where negligence or casual inaction is evident.
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Observed that the State acted in a casual and negligent manner, even after dismissal of the SLP by the Supreme Court.
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Consequently, the review petition was dismissed.
Held
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Gross delay of 5,743 days in filing the review petition was not condonable.
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Government agencies must perform duties with diligence; they are not entitled to undue benefit of delay.
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Review petition dismissed.
Analysis
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Reinforces the principle that law treats State and private parties equally regarding limitation and delay.
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Highlights that condonation of delay is an exceptional remedy, and negligence or casual procedural delay by government cannot justify it.
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Emphasizes the duty of government agencies to act with diligence and commitment in legal proceedings.
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Signals that bureaucratic delays and internal procedural steps cannot shield the State from consequences of gross delay.
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Serves as a cautionary precedent against expecting leniency for delayed filings by government departments.