Delay in filing must be justified with Specific Reasons, not Broad Arguments --- Lahore High Court Dismisses Civil Revision Petition as Time-Barred
Islamabad 14-03-2025: The Lahore High Court has dismissed [Civil Revision No. 1214 of 2017], challenging orders issued by the lower Court on 14.12.2013 and 08.01.2016. The Petitioner sought condonation of delay under Sections 5, 14, & 18 of the Limitation Act, 1908, along with Section 151 of the Code of Civil Procedure (CPC). The Court, however, ruled that the revision petition was barred by limitation and that no sufficient cause was demonstrated to justify the delay.
The Court emphasized that ignorance, negligence, or wrong legal advice cannot override statutory limitation periods. Khushi Muhammad Vs. Mst. Fazal Bibi & Others (PLD 2016 SC 872).
The Petitioner relied on (PLD 2012 SC 400-5-MB) to argue for suo motu intervention, but the Court held that suo motu powers cannot be claimed as a matter of right. Khan Bahadur Khan Vs. Khan Malook Khan (PLD 2022 SC 482).
The Court reaffirmed that delay in filing must be justified with specific reasons, not broad arguments. Saqib Ali Vs. Govt. of Punjab (2023 PLC (C.S.) 310).
The Petitioner’s claim of unjust enrichment was dismissed, as such matters require separate restitution proceedings and cannot be decided in a revisional petition. Sui Northern Gas Pipelines Vs. Deputy Commissioner Inland Revenue (2014 PTD 1939).
The Court ruled that Order XXII, Rule 10 CPC (Devolution of Interest) applies only when a suit is ongoing, not after it has been rejected under Order VII, Rule 11 CPC.
The application for condonation of delay [C.M No. 01 of 2017] was dismissed, and [Civil Revision No. 1214 of 2017] was also dismissed as time-barred. The Court refused to exercise suo motu revisional jurisdiction, reinforcing the importance of adhering to statutory timelines in legal proceedings.
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