Mayo v. Dep't of Commerce
In Mayo v. Dep't of Commerce, 4 Va. App. 520, 358 S.E.2d 759 (1987), the Court held that the time limitation in Rule 2A:4 for filing a petition for appeal was mandatory and the trial court was not authorized to extend the limitation.
The court made an analogy between the rules governing appeals to the Supreme Court and the time requirements for appeals to circuit courts from decisions of administrative agencies.
"Generally, rules governing appeal procedures are mandatory and 'compliance with them is necessary for the orderly, fair and expeditious administration of justice.'" Id. at 522, 358 S.E.2d at 761.