Court emphasizes strict adherence to limitation period under Commercial Courts Act, citing lack of sufficient cause and administrative lethargy as grounds for dismissal.
In a significant ruling delivered on October 9, 2026, the Karnataka High Court (Division Bench comprising Justices Anu Sivaraman and T.P. Vivekananda) dismissed the Commercial Appeal No. 490 of 2024 filed by the Regional Manager, IRCTC, Bengaluru, against Amulya Enterprises. The appeal was filed with a delay of 92 days beyond the prescribed limitation period under Section 13(1A) of the Commercial Courts Act, 2015, and the appellant's request for condonation of delay was refused.
The appellant contended that the delay was caused due to various factors including multiple adjournments of the judgment pronouncement, late awareness of the judgment by counsel, time taken to obtain certified copies, administrative approval delays at the head office, bereavement in counsel's family, and advice to await the outcome of a similar pending appeal. Despite these explanations, the Court found the reasons insufficient to justify condonation of the delay.
Relying heavily on precedents such as the Supreme Court's decision in Government of Maharashtra (Water Resources Department) v. Borse Brothers Engineers and Contractors (P) Limited (2021) 6 SCC 460, the Court reiterated that the object of the Commercial Courts Act is speedy resolution of commercial disputes. The expression "sufficient cause" for condonation of delay cannot be extended to cover negligent, stale, or inadequately explained delays. The Court observed that mere administrative movement of files and vague references to personal circumstances do not constitute sufficient cause. It emphasized that government departments and their instrumentalities are equally bound by limitation laws and must act with due diligence.
The Court also referred to other authoritative judgments, including Postmaster General v. Living Media India Ltd (2012) 3 SCC 563 and Jharkhand Urja Utpadan Nigam Ltd. v. Bharat Heavy Electricals Ltd (2025 INSC 533), underscoring the obligation of litigants and their counsel to monitor proceedings actively and to take timely steps for filing appeals.
The judgment highlighted that the appellant failed to provide detailed particulars regarding the delay at each stage, including when the appeal proposal was placed before the competent authority and when approval was granted. The counsel's impression about adjournments, the bereavement, and the pendency of a similar appeal were found to be vague and unsubstantiated.
Consequently, the Court dismissed the application for condonation of delay and the appeal itself, reinforcing the principle that delay in commercial appeals is to be condoned only in exceptional circumstances and not as a matter of routine.
This ruling serves as a strong reminder for litigants, especially government bodies, to adhere strictly to limitation periods to ensure the efficacy and swift disposal of commercial disputes.
Bottom Line:
Commercial Courts Act - Appeal under Section 13(1A) - Delay of 92 days in filing appeal - Condonation of delay refused - Mere administrative movement of files, obtaining approval from head office, counsel's impression regarding adjournment of pronouncement, pendency of similar matter and vague reference to bereavement do not constitute sufficient cause - In commercial matters, delay beyond prescribed period is to be condoned by exception and not by rule.
Statutory provision(s): Commercial Courts Act, 2015 Section 13(1A), Limitation Act, 1963 Section 5
Regional Manager, IRCTC v. Amulya Enterprises, (Karnataka)(DB) : Law Finder Doc Id # 2998872
