Delay of 1,788 Days in Filing Appeal Led to ₹1 Lakh Cost Being Imposed on State

The Supreme Court of India, delivered a significant judgment addressing systemic delays in filing appeals by State authorities. The bench, comprising Justice J.B. Pardiwala and Justice R. Mahadevan, emphasised the need for accountability and directed all States to streamline their legal machinery to avoid such delays.

The case arose from a dispute concerning government lands in Village Majhganwa, Katni, Madhya Pradesh. The respondent, Ramkumar Choudhary, filed Civil Suit No. 79A/2011 seeking a declaration of title and a permanent injunction over land parcels measuring 1,300 hectares. The trial court, on August 29, 2013, dismissed the suit, holding that the land belonged to the government. However, the Additional District Judge reversed this decision on August 21, 2014, ruling in favor of the respondent.

Despite the adverse ruling, the State of Madhya Pradesh took over five years to file a second appeal. The delay of 5 years 10 months and 16 days (1,788 days) was primarily attributed to lapses in the administrative process. The appellate court’s judgment was communicated to the Collector only after a year, and further delays occurred during the internal approval process, including a three-year delay by the Law Department in granting permission to file the appeal. Consequently, the High Court dismissed the second appeal on January 24, 2024, citing an unjustifiable delay.

The Supreme Court upheld the High Court’s decision, emphasizing the lack of sufficient cause for condoning the delay. Referring to precedents like Majji Sannemma v. Reddy Sridevi (2021 SCC OnLine SC 1260) and Union of India v. Jahangir Byramji Jeejeebhoy (2024 SCC OnLine SC 489), the Court reiterated that delays must be justified within the limitation period and cannot be excused by subsequent events. The bench observed that such lapses reflect a callous attitude by State officials, resulting in significant revenue losses for the government.

To address these recurring issues, the Supreme Court directed all States to fix accountability on officers responsible for delays in legal matters. It ordered States to penalize officials whose negligence causes such lapses, linking penalties to the value of the losses incurred. The Court stated:

“We direct the State to streamline the machinery touching the legal issues, offering legal opinion, filing of cases before the Tribunal/Courts, etc., fix the responsibility on the officer(s) concerned, and penalize the officer(s), who is/are responsible for delay, deviation, lapses, etc., if any, to the value of the loss caused to the Government.”

The Court imposed a cost of ₹1 lakh on the State of Madhya Pradesh, to be deposited with the Supreme Court Mediation Centre within two weeks.

Case Details- State of Madhya Pradesh V. Ramkumar Choudhary