In a significant ruling addressing the balance between procedural timelines and substantive justice, the Supreme Court has held that while delay must be explained with “sufficient cause,” adjudication on merits must not be defeated solely on limitation grounds—especially when public land and State interests are involved.
The judgment was delivered by a Division Bench comprising Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah on March 21, 2025, in Inder Singh vs The State of Madhya Pradesh.
Case Background
The dispute arose over a piece of land measuring 1.060 hectares situated in Village Mohrirai, Tehsil and District Ashoknagar, Madhya Pradesh. The appellant, Inder Singh, filed a suit in 2012 claiming title, possession, and permanent injunction over the land, relying on an alleged allotment order from 1977, which was later corrected in his name in 1978.
The Trial Court dismissed the suit in 2013, but the First Appellate Court reversed the decision in 2015, declaring Inder Singh as the landlord. The State of Madhya Pradesh then filed a Review Petition in 2018, which was dismissed in 2019 on the ground of delay.
Subsequently, the State filed a Second Appeal before the High Court in 2020 with a delay of 1537 days, which was condoned by the High Court. Inder Singh challenged this order in the Supreme Court, leading to the present appeal.
Key Legal Issues
- Whether the High Court erred in condoning a delay of over four years in filing the Second Appeal.
- Whether delay by the State can be treated with greater leniency as compared to private litigants.
- Whether procedural delay should defeat substantive rights in cases involving government land.
Observations of the Supreme Court
Addressing the issue of delay, the Court held:
“There is no doubt that all parties, whether or not State under Article 12 of the Constitution, are required to act with due diligence and promptitude.”
“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 acknowledged that while the delay was substantial—over four years—the issue involved public land allegedly allotted to State departments such as the Youth Welfare Department and the Collectorate, which warranted scrutiny on merits.
Referring to earlier precedents, including Ramchandra Shankar Deodhar v. State of Maharashtra (1974) and Sheo Raj Singh v. Union of India (2023), the Court emphasized:
“Liberal approach does not mean that an appeal should be allowed even if the cause for delay shown is flimsy… However, where the subject matter affects public interest or substantial justice, courts must adopt a balanced view.”
Final Decision
The Supreme Court dismissed the appeal filed by Inder Singh and upheld the High Court’s decision to condone the delay in filing the Second Appeal by the State.
However, to balance equities, the Court imposed costs of ₹50,000 on the respondent State, to be paid to the appellant within one month. Failure to comply would lead to the dismissal of the Second Appeal.
The Court also directed the High Court to give priority to the pending Second Appeal and dispose of it expeditiously.
Importantly, the Supreme Court clarified that its observations are limited to the condonation issue and will not influence the merits of the Second Appeal.
