Jharkhand HC again raps State over bureaucratic lethargy, dismisses 559-day delayed appeal in Anganwadi Sevika case
SUMAN K SHRIVASTAVA Ranchi, July 13: Continuing its tough stand against bureaucratic delays in government litigation, the Jharkhand High Court has once…
SUMAN K SHRIVASTAVA
Ranchi, July 13: Continuing its tough stand against bureaucratic delays in government litigation, the Jharkhand High Court has once again refused to condone an inordinate delay in filing an appeal, dismissing the State government’s challenge to the reinstatement of an Anganwadi Sevika in Deoghar after finding no “sufficient cause” for a 559-day delay.
The Division Bench of Chief Justice M.S. Sonak and Justice Rajesh Shankar rejected the State’s plea for condonation of delay and, consequently, dismissed the accompanying Letters Patent Appeal, holding that routine bureaucratic procedures, movement of files and departmental approvals cannot override statutory limitation periods.
The latest ruling comes less than three weeks after the same Bench dismissed two other delayed government appeals involving delays of 762 days and 475 days, signalling the High Court’s growing impatience with what it has repeatedly described as administrative lethargy in pursuing litigation.
Appeal stemmed from Anganwadi Sevika’s reinstatement
The appeal arose from a Single Judge’s order dated August 9, 2023, in which Justice S.N. Pathak had quashed the termination of Sakila Banu, an Anganwadi Sevika posted at Chandanpura in Deoghar district.
Banu was appointed in 2007 after being selected through an Aam Sabha and served for nearly a decade before her services were terminated in October 2016 on allegations that she had secured the appointment using a forged educational certificate.
Allowing her writ petition, the Single Judge held that the authorities had failed to conduct any proper inquiry before terminating her services and had ignored documents obtained under the Right to Information Act indicating that her educational certificates were genuine and that her name figured in the school’s admission register.
The court also noted that the authorities had accepted her educational qualifications at the time of appointment and could not question them after allowing her to serve for ten years without proper verification. The termination order was quashed, and the State was directed to reinstate her with consequential benefits, including payment of honorarium for the period she remained out of service.
Court finds prolonged periods of unexplained inaction
While challenging the order, the State sought condonation of a 559-day delay. However, the Division Bench found several prolonged periods of complete inactivity.
The court pointed out that there was an unexplained gap of nearly three months before the first step was taken after the Single Judge’s order. It also noted another unexplained delay of about two months even after a decision had been taken to file the appeal, followed by another two-month delay before the matter was assigned to government counsel.
Perhaps most significantly, although the memorandum of appeal had been prepared in July 2024, the appeal itself was filed only in March 2025, leaving nearly eight months entirely unexplained.
The Bench observed that the State’s application merely chronicled the movement of files, legal opinions and departmental approvals without accounting for the long periods during which no effective steps were taken.
Pattern of judicial rebuke
The latest order adds to a series of recent judgments in which the Jharkhand High Court has refused to excuse delayed appeals filed by government departments.
On June 25, the same Division Bench dismissed two Letters Patent Appeals after refusing to condone delays of 762 days and 475 days.
In one case involving the Deoghar Zila Parishad, the court found that the authorities had remained inactive for nearly nine months after the judgment and then allowed the matter to remain pending for another ten months despite obtaining legal opinion.
In the second case concerning the Minor Irrigation Department, the Bench rejected the State’s explanation for a 475-day delay, observing that merely listing departmental approvals, file movement and legal consultations did not establish sufficient cause under the Limitation Act.
Supreme Court precedents reiterated
Reaffirming settled law, the Division Bench once again relied on landmark Supreme Court judgments, including Postmaster General vs. Living Media India Ltd. (2012), Union of India vs. Jahangir Byramji Jeejeebhoy (2024) and Shivamma vs. Karnataka Housing Board (2025).
The High Court reiterated that government departments cannot claim preferential treatment under limitation law and emphasised that “administrative lethargy and laxity” can never constitute sufficient cause for condoning inordinate delay.
The Bench also underlined that courts should not legitimise bureaucratic inaction by routinely condoning delays, as doing so prolongs litigation and deprives successful litigants of the benefits of favourable judicial orders.
With the dismissal of the appeal, the Single Judge’s order directing Sakila Banu’s reinstatement with consequential benefits remains undisturbed.
