Case Name: Inder Singh vs. State of Madhya Pradesh

Case Number: Civil Appeal No. (Arising out of SLP (Civil) No. 6145 of 2024)

Date: March 21, 2025

Quorum: Hon’ble Justice Sudhanshu Dhulia & Hon’ble Justice Ahsanuddin Amanullah

 

FACTS OF THE CASE

 

The appellant, who is Mr. Inder Singh in the said case had filed a civil suit before the Second Additional District Judge, Class-1, Ashoknagar, Madhya Pradesh, seeking declaration of title, possession, and permanent injunction over a parcel of land which was (Survey No. 8/1) measuring 1.060 hectares. The land was mistakenly recorded in the revenue records under another individual’s name but was later corrected through an order by the Additional Collector, Gwalior. However, the State subsequently declared the land as government property. The Trial Court dismissed the suit in 2013. On appeal, the First Appellate Court had further ruled in favor of the appellant in 2015. The court had declared him as the owner. The respondent-State had filed a review petition in 2018, which was dismissed due to the delay in the filing. In 2020, the State had filed a Second Appeal before the High Court along with an application the seeking condonation of delay, which was granted. Aggrieved by this, the appellant approached the Supreme Court.

ISSUES

 

1. Whether the High Court was justified in condoning the delay of 1537 days in filing the Second Appeal.
2. Whether the delay in filing the appeal, considering the public nature of the land, should be viewed with leniency.
3. Whether the matter requires adjudication on merits despite the lapse of limitation.

LEGAL PROVISIONS

 

1. The Section 51 of the Limitation Act, 1963 – It primarily governs the extension of the prescribed period for filing an appeal if ‘sufficient cause’ is being shown as the case maybe.
2. Article 123 of the Constitution of India – Defines the scope of state authority and its obligations in legal proceedings.

ARGUMENTS

 

Petitioner’s Arguments:

 

1. The High Court failed to justify how ‘sufficient cause’ was made out for condoning the delay.
2. The delay was not due to COVID-19, as the cause of action arose much earlier.
3. The State’s negligence in not filing the appeal within time should not be overlooked.
4. Relying on State of U.P. v. Satish Chand Shivhare, he argued that condoning delays caused by red tape should not become routine.

 

Respondent’s Arguments:

 

1. The delay occurred due to a combination of factors, including the need to pursue a review petition and the disruptions caused by the COVID-19 pandemic.
2. The land in question is government property, and public interest outweighs procedural lapses.
3. Courts have taken a liberal approach in cases where substantial justice is at stake, citing State of Bihar v. Kameshwar Prasad Singh (2000) 9 SCC 94.
4. The matter involves valuable government land, and the case should be decided on merits rather than being dismissed due to limitation.

 

ANALYSIS

 

The delay of 1537 days is significant; however, it includes time taken for filing and dismissal of a review petition. The State’s claim that the land is public property necessitates a deeper judicial examination rather than summary dismissal. Unlike private disputes, government land disputes impact the public at large. The Court must ensure that a procedural delay does not deprive the State of the opportunity to reclaim land meant for public purposes.

While limitation laws must be enforced, they should not defeat substantial justice when the case involves potential public land misappropriation. In Ramchandra Shankar Deodhar v. State of Maharashtra (1974) 1 SCC 317, the Supreme Court ruled that the rule against stale claims is discretionary and should be relaxed in cases affecting public interest.

 

JUDGEMENT

 

1. The Supreme Court upholds the High Court’s decision to condone the delay in filing the Second Appeal.
2. However, the Court imposes costs of Rs. 50,000/- on the respondent-State, payable to the appellant within one month, failing which the Second Appeal shall stand dismissed.
3. The High Court is directed to prioritize the Second Appeal and dispose of it expeditiously.
4. The present judgment does not preclude either party from raising factual and legal contentions in the High Court.

 

CONCLUSION

 

The Court finds that the condonation of delay is justified, considering the nature of the land dispute and the public interest involved. However, the State must ensure due diligence in future litigation. By allowing the appeal to proceed on merits rather than being dismissed on technical grounds, the Court aims to achieve a fair balance between limitation laws and substantial justice.

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WRITTEN BY POOJA PARAMESWARAN