A party cannot use a civil suit to obtain relief denied in criminal proceedings.

The petitioner sought review of the order dated 24 August 2018 in Civil Revision No. 95 of 2017, by which the respondent’s revision was dismissed on the ground that the suit disclosed no cause of action

In the suit, the petitioner sought declarations that specified documents and related acts were forged and void, and also claimed ₹10,000 in compensation

The petitioner had pursued criminal complaints concerning the alleged forgery; those proceedings, including a petition under Section 482 of the Code of Criminal Procedure, were dismissed

In the review petition, he argued that the civil suit should proceed to a decision on the merits and sought recall of the 2018 order

1. Whether the petitioner established a recognised ground for reviewing the order dated 24 August 2018 in Civil Revision No. 95 of 2017

2. Whether granting the declaratory relief sought in the civil suit would impermissibly revive or frustrate the criminal proceedings between the parties

Relying on Kamlesh Verma v. Mayawati, (2013) 8 SCC 320, the Court stated that review may be granted for discovery of new and important evidence despite due diligence, an error apparent on the face of the record, or another sufficient reason analogous to those grounds

Review is not an appeal in disguise: repetition of rejected arguments, a mere possibility of another view, or an error requiring detailed examination does not suffice

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

Under State of West Bengal v. Kamal Sengupta, (2008) 8 SCC 612, an error apparent must be prima facie visible without detailed examination; an erroneous view of law is not, by itself, a ground for review

The Court found no apparent error in the order under review and treated the petitioner’s arguments as insufficient to meet the limited review standard

It further reasoned that granting the requested civil relief would effectively restore a criminal case that had concluded in the respondent’s favour, and could frustrate the criminal proceedings; the petitioner could not obtain through the civil suit the same relief denied in the criminal proceedings

dismissed the review petition as without merit