A review petition cannot reopen an order absent an error apparent on the record.

Respondent No. 6 had obtained an order in WPS No. 2713 of 2026 directing the concerned authority to conclude proceedings in Case No. 202503111700107/A-76/2022-23 expeditiously, preferably within four months.

Uniworth sought review, contending that its application under Order IX Rule 13 CPC to set aside an ex parte order dated 22.07.2022 remained pending before the Controlling Authority/Assistant Labour Commissioner, while the Tahsildar had issued an attachment order dated 17.08.2026.

It argued that attachment proceedings should not be completed before that application was decided.

The Court had not determined the merits of the original writ petition; it had directed completion of the pending proceeding.

1. Whether the pending application under Order IX Rule 13 CPC and the subsequent attachment order disclosed an error apparent on the face of the record warranting review of the order dated 17.04.2026.

2. Whether the review petition could be used to obtain reconsideration of the original order where no ground under Order XLVII Rule 1 CPC was established.

Under Order XLVII Rule 1 CPC, review is available on discovery of new and important matter or evidence which, despite due diligence, was not previously within the applicant’s knowledge, an error apparent on the face of the record, or another sufficient reason analogous to those grounds.

An error is apparent only when it is self-evident and does not require a long-drawn process of reasoning or reappreciation of evidence; review is not an appeal in disguise and cannot be used merely because another view is possible.

The Court relied on Smt. Meera Bhanja v. Smt. Nirmala Kumari Choudhury, AIR 1995 SC 455.

Asharfi Devi (Dead) through LRs v. State of Uttar Pradesh, (2019) 5 SCC 86, reiterates that an error must be apparent on the face of the record to attract Order XLVII Rule 1 CPC.

The Court treated the applicant’s contention—that its Order IX Rule 13 application remained pending and attachment had been initiated—as insufficient to establish an apparent error in the earlier order.

The order under review had simply directed the authority to conclude the pending proceeding in accordance with law, after the State informed the Court that the proceeding had resumed.

Since the review grounds would require reconsideration rather than reveal a self-evident error in the earlier order, they fell outside the limited scope of review.

It dismissed the review petition as without merit.