Review Application Cannot Be Entertained to Reargue Merits or Correct Alleged Errors in Adjudication

The review applicants (original applicants in O.A. No. 1446/2016) filed a Review Application under Section 22(3)(f) of the Administrative Tribunals Act, 1985, seeking to review the Tribunal's order dated 12.03.2026

The applicants sought to challenge the findings of the original order by reiterating arguments previously submitted during the adjudication of the O.A.

The matter was decided in circulation by the Principal Bench.

1. Whether the review applicants established any "error apparent on the face of the record" or discovered new material evidence that would justify a review of the order dated 12.03.2026 under the Administrative Tribunals Act

The Tribunal applied Section 22(3)(f) of the Administrative Tribunals Act, 1985, read with Rule 17 of the CAT (Procedure) Rules, 1987, and Order XLVII, Rule 1 of the Code of Civil Procedure (CPC), which restricts the scope of review to cases involving an error apparent on the face of the record, discovery of new evidence (post-due diligence), or other sufficient reasons

It further relied on the doctrine of stare decisis and the precedent set in Union of India v. Tarit Ranjan Das (2004 SCC (L&S) 160), which holds that a review is not a substitute for an appeal and cannot be used to re-argue the merits of a case

The Tribunal found that the review applicants failed to satisfy the narrow statutory requirements for a review.

It observed that the applicants merely reiterated submissions and pleas that had already been duly considered and adjudicated in the original order dated 12.03.2026

The court reasoned that even if an order is perceived as wrong or erroneous, it does not constitute a ground for review unless there is a patent error on the face of the record

Since the applicants could not produce any new documents that were previously unavailable or point to an obvious clerical or legal error, the Tribunal concluded that the applicants were attempting to "reargue the matter," which is legally impermissible in a review proceeding

The court clarified that if the applicants are dissatisfied with the merits of the order, the appropriate remedy lies in a higher forum (appeal) rather than a review application