A review petition cannot reopen a settled ruling absent a recognised ground for review.

The Municipal Corporation sought review or recall of the common order dated 14 August 2024, passed in a batch of writ appeals including W.A. No. 447 of 2018.

Its counsel acknowledged that the same issue had been considered in R.P. No. 2473 of 2025 and connected cases, dismissed by order dated 13 July 2026.

The Court found the present controversy covered by that decision.

1. Whether the review petition disclosed a basis for review or recall of the common order dated 14 August 2024 under the principles governing review jurisdiction.

2. Whether the controversy was governed by the decision in R.P. No. 2473 of 2025 and connected cases.

Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure permits review on specified grounds, including discovery of new and important matter despite due diligence, an error apparent on the face of the record, or another sufficient reason.

Review is not an appeal in disguise: it cannot be used to rehear a matter or substitute a different view, and an error requiring lengthy reasoning is not an error apparent.

The Court relied on the principles in Inderchand Jain v. Motilal, Lily Thomas v. Union of India, Haridas Das v. Usha Rani Banik, Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, Meera Bhanja v. Nirmala Kumari Choudhury, and Parsion Devi v. Sumitri Devi.

The Court did not undertake a fresh examination of the underlying writ appeals.

It noted that the petitioner’s counsel accepted that the same issue had already been decided in the related review proceedings, and held that the present controversy was squarely covered by that decision.

Applying that decision on the same terms, the Court concluded that the present petition should also be dismissed.

The order dated 13 July 2026 in R.P. No. 2473 of 2025 and connected cases was directed to apply mutatis mutandis to this case.