Dismissal of Special Leave Petition does not attract doctrine of merger, allowing maintainability of review petitions.

The respondents were appointed as daily wagers between 1985 and 1986 and were regularized by the Municipal Corporation Jabalpur on December 25, 2003.

Following complaints regarding seniority violations, a committee report dated April 14, 2005, led to their de-regularization on August 10, 2005.

Ultimately, a Single Bench and subsequently a Division Bench (W.A. No. 391/2018) upheld the regularization.

The petitioner’s Special Leave Petition (SLP No. 21616/2025) was dismissed by the Supreme Court without specific liberty to file a review.

The petitioner now seeks a review of the High Court’s order dated August 14, 2024, alleging non-compliance with the Uma Devi judgment.

1. Whether a review petition is maintainable before the High Court after the dismissal of a Special Leave Petition (SLP) by the Supreme Court in the absence of specific liberty.

2. Whether the earlier judgment upholding regularization suffered from an error apparent on the face of the record regarding the application of the State of Karnataka v. Uma Devi principles.

Doctrine of Merger, noting that dismissal of an SLP in limine (without reasons) does not attract the doctrine, thus preserving the maintainability of a review petition as established in Khoday Distilleries Ltd. v. Sri Mahadeshwara Sahakara Sakkare Karkhane Ltd. and Kunhayammed v. State of Kerala.

Order 47 Rule 1 of the CPC and Shri Ram Sahu v. Vinod Kumar Rawat, which restrict review to "errors apparent on the face of the record" rather than a re-hearing on merits.

Bhola Nath v. State of Jharkhand, emphasizing that a "model employer" cannot use contractual labels or mechanical applications of Uma Devi to justify prolonged ad-hocism.

The court first affirmed that the review petitions were legally maintainable because the Supreme Court’s dismissal of the SLP did not result in a merger of orders.

On the merits of the review, the court found that the petitioner was merely attempting to re-argue points already considered and decided by both the Single and Division Benches.

The court reasoned that the petitioner sought an "appeal in disguise," which is impermissible under Order 47 Rule 1.

The court observed that the respondents had served for 30–40 years, and the Municipal Corporation, as a model employer, cannot arbitrarily discard long-serving employees by misapplying the Uma Devi precedent.

The court answered the issues by dismissing the review petitions and affirming the respondents' regularization.

The court further directed the Municipal Corporation to consider the cases of any similarly situated daily wagers who were left out under the State's Vinaymitikaran Policy dated June 10, 2017.