16 June 2025 Consumer Protection Act >> Consumer Rights  

In Agriculture Insurance Company of India Through Its Deputy Manger v/s Aadim Jati Prathmik Krishi Sakh Sewa Sahakari Samiti Maryadit Chilkapur & Others the Commission has dismissed several Second Appeals due to inordinate delays, ranging from 233 to 253 days beyond the statutory 30-day period for filing such appeals. The grounds cited for condonation of delay—namely, approval from higher authorities, procurement and translation of documents, redrafting of appeals, and the counsel's illness—were deemed insufficient to justify such significant delays.

The Commission emphasized that condoning such delays in consumer complaints would defeat the very purpose and spirit of the Consumer Protection Act, which mandates time-bound resolution of disputes.

Reliance was placed on several Supreme Court judgments to underscore the strict application of limitation periods in consumer matters:

• Anshul Aggarwal vs. New Okhla Industrial Development Authority: This ruling highlights that the special limitation period in the Consumer Protection Act is intended for expeditious adjudication, and entertaining highly belated petitions would undermine this objective.
• Basavraj & Anr. Vs. The Spl. Land Acquisition Officer: This judgment defines "sufficient cause" as a reason for which the applicant cannot be blamed, emphasizing that the party must not have acted negligently or lacked bona fide intention. It reiterates that courts cannot extend limitation periods on equitable grounds, even if the law appears harsh.
• Lingeswaran Etc. vs. Thirunagalinman: This case reinforced that if a delay is not properly explained, and there's no merit in the condonation application, it should be dismissed. Condoning such delays would effectively reward negligence.
• Brijesh Kumar & Ors. vs. State of Haryana & Ors. and P.K. Ramachandran v. State of Kerala & Anr.: These judgments reiterate the legal maxim "Interest Reipublicae Ut Sit Finis Litium" (it is for the general welfare that a period be put to litigation) and affirm that limitation laws, though sometimes harsh, must be applied rigorously, and courts lack the power to extend periods on equitable grounds.

In light of these precedents and a careful review of the condonation applications, the Commission concluded that no "sufficient cause" was provided to justify the extensive delays. Consequently, the Second Appeals were dismissed as barred by limitation.

  Consumer Protection Act, 1986