Inordinate Unexplained Delay In Service Claims Attracts Principle Of Laches And Bars Relief: MP HC

Madhya Pradesh High Court: A single judge bench consisting Justice Vishal Mishra dismissed a petition seeking time-bound promotion benefits under the 1999 scheme, holding that inordinate delay without explanation bars relief under principles of laches. The court found that the 14-year delay between retirement and petition filing, with no substantial efforts to claim benefits during service or immediately after retirement, disentitled the petitioner from discretionary relief. The court emphasized that while delays may be condoned with proper justification, gross negligence in pursuing claims cannot be rewarded.

Background

The petitioner, Smt. Rajkumari Soni, sought time-bound promotion benefits for her late husband, who was employed as a Timekeeper/Sthal Sahayak from 1973 until his retirement in 2010. The petitioner argued that her husband was not granted the benefit of Kramonnati (time-bound promotion) under the 1999 scheme, despite multiple representations made during his service tenure. After her husband passed away in 2021, the petitioner made further representations in 2024, but no action was taken by the respondents.

The petitioner contended that other employees similarly situated had received such benefits, and hence her late husband should also be extended the same. The petitioner urged that denying these benefits was unjust, particularly as her husband had rendered long, continuous service without any career progression.

Arguments

The petitioner argued that her late husband had worked diligently for over three decades without receiving any promotion. She cited previous court decisions that had granted similar relief to other employees. She claimed that despite repeated requests, her husband's claim for promotion had been ignored during his lifetime and that this court should now intervene and direct the respondents to grant the benefits, including interest on the delayed payment.

The State, represented by the Deputy Advocate General, opposed the petition primarily on grounds of delay. The respondents argued that the petition was filed 14 years after the petitioner's husband had retired, with no proper explanation for this substantial delay. They asserted that under well-established legal principles, claims marred by excessive delay and inaction are barred by laches and cannot be entertained. The respondents urged the court to dismiss the petition on these grounds.

Court's Reasoning

The petitioner's husband had retired in 2010, and no effort was made by him during his service or immediately after his retirement to seek the time-bound promotion under the 1999 scheme. Instead, the claim was brought for the first time in 2024, nearly 14 years after his retirement and more than three years after his death, with no explanation for the delay.

The court cited the Supreme Court decision in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy [(2013) 12 SCC 649], emphasizing that while courts can adopt a liberal approach in condoning delays, they must ensure that the delay is not due to gross negligence or indifference on the part of the litigant. The court observed that this principle did not apply here because the petitioner's husband had ample opportunity to claim his rights during his lifetime but failed to do so. The court also noted that the petitioner herself remained inactive for over three years following her husband's death before filing the writ petition.

The court further referred to State of Orissa & Anr. v. Mamata Mohanty [(2011) 3 SCC 436], which held that a petitioner cannot simply rely on favorable rulings in similar cases after an unreasonable delay, as this would encourage indolence and weaken the effectiveness of legal processes. In this context, the court held that the petitioner's delay of more than a decade barred her claim.

Additionally, the court pointed out that even if the petitioner's claim were considered on merit, there was no documentary evidence showing that the petitioner's husband had made any formal representation or claim for promotion during his service period. This further weakened her case. The court concluded that reopening a stale claim after such a long period would undermine the principles of equity and fairness, particularly when other similarly situated individuals who acted diligently had already received their entitlements. In dismissing the petition, the court stressed that equitable relief is not available to those who remain idle or negligent in asserting their rights, particularly in cases where there is an unexplained and significant delay.

Neutral Citation: 2024:MPHC-JBP:52228 (Smt Rajkumari Soni v. The State of Madhya Pradesh)

Citation: 2024 LiveLaw (MP) 268

Date: October 18, 2024

Counsel for the Petitioner: Shri Sanjay Roy

Counsel for the Respondent: Shri Yash Soni, Deputy Advocate General

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