Relief granted to others does not create negative parity or establish an error apparent warranting review.

The petitioner, a contractual Sub-Engineer under the MGNREGA scheme, sought review of the High Court’s order dismissing his writ petition against the non-extension of his contractual engagement.

He argued that the decision was based on misconduct allegations and was stigmatic, and that similarly situated Sub-Engineers had obtained relief in separate proceedings.

The State opposed review, contending that the petitioner had no vested right to renewal and had shown no apparent error.

The Court examined the petitioner’s appellate order alongside appellate orders concerning other Sub-Engineers, noting their differing factual findings and grounds.

1. Whether the dismissal of the petitioner’s writ petition disclosed an error apparent on the face of the record warranting review under Order XLVII Rule 1 CPC

2. Whether relief granted to other Sub-Engineers in separate proceedings entitled the petitioner to the same relief in review

3. Whether K. Raghupathi v. State of U.P. required review of the dismissal order in the petitioner’s case

Section 114 and Order XLVII Rule 1 CPC permit review on discovery of new and important evidence unavailable despite due diligence, 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; an error must be patent and self-evident, rather than one requiring reappraisal or extended reasoning.

State of West Bengal v. Kamal Sengupta similarly holds that an apparent error must be prima facie visible and that an erroneous view of law is not, by itself, a ground for review.

Parsion Devi v. Sumitri Devi and Col. Avatar Singh Sekhon v. Union of India confine review to material, manifest errors that undermine the decision or cause a miscarriage of justice.

Article 14 does not permit a claim to “negative parity” based on an allegedly erroneous benefit granted in another case, as stated in Basawaraj v. Special Land Acquisition Officer and State of Odisha v. Anup Kumar Senapati.

The Court treated K. Raghupathi v. State of U.P. as fact-specific.

The Court found that the petitioner’s arguments about the alleged stigmatic basis for non-extension, his APR gradings, and the treatment of other Sub-Engineers did not establish a patent error in the dismissal order; they invited reconsideration of the merits, which is beyond review jurisdiction.

The appellate orders concerning other Sub-Engineers arose from their individual facts and findings and could not be mechanically applied to the petitioner, nor could they create a right to equal treatment if the relief granted was not otherwise legally due.

K. Raghupathi did not alter that conclusion because its result depended on the circumstances of that case.

It dismissed the review petition as devoid of merit.