A review petition cannot reopen disputed factual issues reserved for determination by the competent committee.

The petitioner sought review of the order dated 22 July 2026 in W.P. No. 22125 of 2026.

In that order, the Court had quashed the Director of Horticulture’s order concerning an alleged fourth violation of the Operational Guidelines for Per Drop More Crop, 2025 (“PDMC 2025”), and left the matter to the State Level Sanctioning Committee (“SLSC”) for consideration under Clause 17.3(iv).

The petitioner argued that the samples had not been collected in its or its representative’s presence, contrary to Clause 18.4, and that it should have been given an opportunity to pay the prescribed penalty before cancellation.

Whether the petitioner established a ground for review by contending that it should have been allowed to pay a penalty applicable to an earlier category of violation.

Whether the alleged non-compliance with Clause 18.4 of PDMC 2025 could be determined in the review proceedings, or should be raised before the SLSC.

Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure confine review to recognised grounds, including an error apparent on the face of the record; review is not an appeal permitting fresh adjudication, reappreciation of evidence, or re-argument of the case.

Under Clause 17.3(iv) of PDMC 2025, an alleged fourth-time violation is to be placed before the SLSC for consideration; the penalty provisions for earlier violations do not determine the consequence of a fourth violation.

Questions concerning compliance with Clause 18.4, including the manner of sample collection and the presence of the petitioner or its representative, involve factual matters for examination by the competent authority.

The Court held that the penalty argument did not disclose an error apparent because Clause 17.3(iv) specifically required the alleged fourth violation to be considered by the SLSC, and the consequences of that violation remained for the SLSC to determine.

The challenge to sample collection raised disputed factual questions that could not appropriately be resolved in review.

Since the remand did not prevent the petitioner from raising those objections, the petitioner could place supporting material before the SLSC, which was required to consider them under the applicable Guidelines.

It left the petitioner at liberty to raise permissible contentions, including alleged non-compliance with Clause 18.4, before the SLSC, which must consider them in accordance with law before making its decision.

dismissed the review petition.