A review cannot reopen contractual non-renewal absent an error apparent on the record.

The petitioner, appointed as Additional Programme Officer in 2006, had his contract renewed periodically until 2024–25. Although show-cause notices concerning alleged irregularities in MGNREGA works were issued and answered, no departmental enquiry or finding of misconduct followed. His contract was not extended for 2025–26 by an order dated 28 January 2026.

After the High Court dismissed his writ petition challenging the non-extension, he sought review of that decision, relying on K. Raghupathi v. State of U.P. and orders in favour of similarly situated employees.

The State opposed review, arguing that the petition sought a rehearing and disclosed no error apparent on the face of the record.

1. Whether the petitioner established an error apparent on the face of the record, or another ground under Order XLVII Rule 1 CPC, warranting review of the order dismissing his writ petition.

2. Whether K. Raghupathi or the treatment of other contractual employees disclosed a basis for review of the petitioner’s non-extension.

Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure permit review on discovery of new and important matter or evidence, an error apparent on the face of the record, or another sufficient reason.

Under Kamlesh Verma v. Mayawati, review is not an appeal in disguise or a rehearing on the merits; an error must be manifest and not one requiring a process of reasoning to discover.

State of West Bengal v. Kamal Sengupta, Col. Avatar Singh Sekhon v. Union of India, and Parsion Devi v. Sumitri Devi similarly require a patent error that undermines the decision or risks miscarriage of justice.

K. Raghupathi v. State of U.P. concerned an employee whose contractual appointment and benefits were, in the circumstances of that case, treated as equivalent to those of a regular employee, and whose discontinuance was stigmatic.

Article 14 does not permit “negative parity”: an erroneous or irregular benefit granted to another person cannot be claimed as a right (Basawaraj v. Special Land Acquisition Officer; State of Odisha v. Anup Kumar Senapati).

The Court held that the petitioner’s submissions about the allegations, the absence of an enquiry, and the treatment of other employees sought reconsideration of the merits rather than identifying a patent error in the order under review.

It distinguished K. Raghupathi because the petitioner was not shown to have been treated as a regular employee or given equivalent benefits, and because the non-extension order was not stigmatic.

The decisions concerning other employees did not establish a review ground, since Article 14 cannot support a claim to negative parity.

Applying the limited review standard, the Court found no apparent error warranting interference.

The review petition was dismissed as devoid of merit.