The legal issue that the Supreme Court had to address was whether a delay of such a magnitude could be condoned. The specific legal questions that the Court examined included:

1. Whether the delay of 12 years and 158 days could be justified based on the merits of the case alone?
2. What is the standard for condoning delays in the context of judicial proceedings, and should the length of delay be disregarded if the case appears strong on its merits?
3. What role do procedural requirements play in ensuring the timely adjudication of disputes, and should the failure to comply with these procedures necessarily preclude the granting of relief?

Supreme Court’s Judgment: Key Findings

The bench hearing the case was led by Justices Aniruddha Bose and J.B. Pardiwala. The Court held that while the merits of the case were indeed significant, they could not be the sole determining factor in deciding whether to condone a delay. The Court reinforced the idea that judicial efficiency, fairness, and adherence to procedural rules are integral to the functioning of the justice system.

1. Delay Must Be Justified by Sufficient Reasons: The Supreme Court emphasized that inordinate delays in filing petitions, including restoration applications, must be explained adequately. The applicant’s failure to provide compelling reasons for the delay, despite the fact that the underlying dispute may have substantial merit, was a key consideration in the Court’s decision. Justice Bose stated that the Court cannot allow delays to be condoned merely because the case presents an arguable point of law or a dispute of significant public or private importance.
2. Role of the High Court’s Decision: The Supreme Court upheld the High Court’s decision to not condone the delay. The High Court had rejected the restoration application on the grounds that the Union of India failed to meet the burden of explaining why such a significant delay had occurred. The Court reinforced the principle that high courts and lower courts should not hesitate to dismiss applications for restoration if the delay is not sufficiently justified.
3. Procedural Discipline: The ruling underscores the importance of procedural discipline in judicial proceedings. While access to justice is a fundamental right, the Court noted that the delay in seeking legal recourse—without valid and justifiable reasons—disrupts the timely delivery of justice. The Court observed that such delays can lead to the undue prolongation of legal disputes, making it difficult for the legal system to function efficiently and equitably.
4. Reaffirmation of Legal Precedents: The judgment relied heavily on earlier precedents that set the bar for condoning delays. The Court referred to cases where the condonation of delay was allowed only when a party presented a satisfactory explanation supported by reasonable and plausible grounds. The Court stated that “the mere fact that the case might have merit is not enough to justify delay.”