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Supreme Court of India 2025-01-08 allowed

H.GURUSWAMY & ORS. … vs A. KRISHNAIAH SINCE DECEASED BY LRS. …

Bench: 2 — J. B. Pardiwala, R. Mahadevan

In Brief

This case concerns the principles governing condonation of delay in civil litigation. The respondents filed a recall application nearly six years after a suit was dismissed for abatement, seeking to revive a property dispute that originated in 1977—a suit already rejected on merits in two prior proceedings. The High Court condoned the delay to achieve substantial justice, but the Supreme Court reversed this, holding that rules of limitation rest on public policy and equity, not mere technicality. Courts cannot allow parties to fix their own limitation periods through delayed condonation applications. Unexplained inordinate delays cannot be overcome by invoking 'substantial justice'; the Court must first verify the bona fides of the explanation offered. The appeal was allowed and the Trial Court's rejection of the recall application was restored.

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Civil Procedure Limitation Condonation of Delay Res Judicata Abatement Judicial Discretion

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