A later document investigation does not constitute sufficient cause to condone an unexplained 510-day review delay.

The petitioner sought review of the judgment dated 22 August 2024 in Writ Appeal No. 939 of 2024, filing the review petition 510 days late.

To explain the delay, she relied on an affidavit stating that further investigation into title and documents had been undertaken after the judgment and that additional documents were found.

The affidavit also reiterated grounds already considered in the writ appeal.

The State opposed condonation, contending that sufficient cause had not been shown.

1. Whether the petitioner established sufficient cause to condone the 510-day delay in filing the review petition.

2. Whether the grounds raised in the review petition could be entertained where they substantially re-argued matters already decided in the writ appeal.

The petition was brought under Section 114 read with Order XLVII Rule 1 of the Code of Civil Procedure, 1908.

A review petition must satisfy the requirements of review jurisdiction and cannot be used to re-argue grounds already considered and decided; an applicant seeking condonation of delay must also establish sufficient cause.

The Court found that the affidavit primarily repeated grounds already adjudicated in the 2024 judgment and gave no particulars of the additional documents said to justify review.

It held that post-judgment investigation and the asserted discovery of unspecified documents did not explain the 510-day delay sufficiently.

It further observed that the review grounds substantially sought to re-argue the writ appeal, which was impermissible in review jurisdiction.

It dismissed the review petition on the ground of delay and laches, without granting review of the 2024 judgment.