01Facts
The Applicant, a post-graduate law student, was barred by Maharashtra National Law University (MNLU), Sambhajinagar, from appearing in her second-semester examinations due to a failure to meet the mandatory 75% attendance requirement under the University Regulations 2020.
¶ 2The Applicant previously challenged this via Writ Petition (WP/4881/2026), which was dismissed on 30.04.2026.
¶ 3The Applicant subsequently filed this review application under Order XLVII of the CPC, seeking to reopen the matter, conduct a special examination, and produce new medical evidence and attendance records.
¶ 4-502Issues
i.1. Whether there exists an "error apparent on the face of the record" regarding attendance computation and relaxation rules to warrant a review of the judgment.
¶ 8(a), 11.3(a)ii.2. Whether the applicant can introduce new evidence (medical papers and attendance sheets) in a review petition that was within her knowledge during the original writ proceedings.
¶ 11.3(b), 11.3(f)iii.3. Whether the doctrine of proportionality or subsequent interim orders of superior courts in unrelated cases justify a review of the finalized judgment.
¶ 11.3(g)-(h)03Law Applied
The Court primarily applied Order XLVII Rule 1 of the Code of Civil Procedure (CPC), 1908, which restricts the grounds for review to the discovery of new/important evidence (not available despite due diligence), a mistake or error apparent on the face of the record, or any other sufficient reason.
¶ 11.1It relied on the principles from Lily Thomas v. Union of India and Government of NCT of Delhi v. K. L. Rathi Steels Limited, which establish that a review is not an "appeal in disguise" and that subsequent shifts in law or developments do not constitute grounds for review.
¶ 11.6It further applied the Maharashtra National Law University Regulations 2020 and the PG Academic Committee Resolution, which mandate 75% attendance but permit a relaxation down to 67% on medical grounds.
¶ 10(c), 11.3(a)04Reasoning
The Court found no "error apparent" as the Applicant’s attendance (max 51.12%) fell significantly below both the mandatory 75% and the relaxation threshold of 67%.
¶ 11.3(c), 11.3(g)The Court rejected the Applicant’s attempt to introduce "new" Ayurvedic medical documents, noting they were in her custody during the Writ Petition and their omission indicated a lack of due diligence.
¶ 11.3(f), 11.8(B)Regarding procedural impropriety in the Grievance Redressal Committee, the Court noted the Applicant admitted to not attending the meeting, yet leveled reckless allegations against the committee, which it termed an "abuse of process".
¶ 11.3(d), 11.8(A)The Court emphasized that a review cannot be used to re-argue the merits of the case or to fill lacunae in the original pleadings.
¶ 11.4, 11.505Holding
The Court dismissed the Review Application, holding that the Applicant failed to meet the statutory requirements of Order XLVII of the CPC.
¶ 12The Court held that the prayers for a special examination were beyond the scope of review powers.
¶ 11.5The Court expressed serious displeasure at the Applicant’s "reckless and irresponsible" allegations against university faculty and batch-mates and directed the Registry to mask the name of the Applicant's batch-mate to protect his privacy.
¶ 11.8, 11.12, 12(ii)Original Court PDF
Ankita Jagannath SonawalevsMaharashtra National Law University Thr Its Registrar And Ors
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