A concluded settlement cannot be reopened in review absent an apparent error on the record.

The underlying miscellaneous petitions were disposed of by an order dated 31 October 2023 in terms of a settlement between the parties.

The parties had filed settlement applications, appeared before the Principal Registrar, and confirmed their identities and intention to settle.

On 16 March 2026, some legal representatives of the petitioners sought review, stating that they wished to continue the litigation.

1. Whether the settlement-based disposal disclosed an error apparent on the face of the record warranting review.

2. Whether the review petition, filed more than two years after the settlement order at the instance of some of the petitioners’ legal representatives, met the requirements for review.

Review jurisdiction is limited to grounds such as discovery of new and important matter despite due diligence, an error apparent on the face of the record, or another sufficient reason analogous to those grounds. A review is not an appeal in disguise; it cannot be used to reargue concluded issues or correct an alleged error requiring detailed examination. The Court relied on Kamlesh Verma v. Mayawati, (2013) 8 SCC 320, for the principles governing review.

Chhajju Ram v. Neki, (1921–22) 49 IA 144, and Moran Mar Basselios Catholicos v. Most Rev. Mar Poulose Athanasius, AIR 1954 SC 526, on the meaning of “any other sufficient reason”.

State of West Bengal v. Kamal Sengupta, (2008) 8 SCC 612, for the rule that an error apparent must be prima facie visible and not require detailed examination.

The Court found that the settlement was supported by applications and by the parties’ appearance before the Principal Registrar, who reported that a settlement had been reached. It therefore saw no basis to doubt the settlement or identify an apparent error in the disposal order.

The petitioners’ wish to resume litigation did not establish a recognised ground for review; the Court also noted the delay of more than two years and that the petition was brought by legal representatives of some petitioners.

It dismissed the review petition as misconceived.