Review cannot reopen issues already considered absent an error apparent on the record.

The respondents brought a civil suit seeking recovery of ₹14,87,500 and damages, alleging that the petitioner had received ₹11 lakh towards preliminary expenses for a proposed partnership business that was never formed.

The trial court found that the respondents had paid ₹11 lakh under Ex. P/1 and awarded the amount with interest if it was not repaid within three months; the petitioner’s first appeal was dismissed, while the respondents’ cross-objections were allowed to grant interest from 15 July 2011.

The petitioner sought review of the appellate judgment, arguing, among other things, that Ex. P/1 was inadmissible for insufficient stamp duty and that the suit was barred under Section 69 of the Partnership Act, 1932.

Whether the review petition established an error apparent on the face of the record or another ground warranting review under Order XLVII Rule 1 CPC.

Whether the petitioner’s objections concerning the admissibility of Ex. P/1 and the maintainability of the suit justified review of the appellate judgment.

Section 114 and Order XLVII Rule 1 CPC permit review on limited grounds, including discovery of new and important evidence, an error apparent on the face of the record, or another sufficient reason.

Under Kamlesh Verma v. Mayawati, review is not a rehearing or an appeal in disguise.

Under Moran Mar Basselios Catholicos v. Most Rev. Mar Poulose Athanasius, a review cannot reopen concluded arguments or reassess evidence, and the error must be manifest and material.

State of West Bengal v. Kamal Sengupta and Arun Dev Upadhyaya further establish that an apparent error must be evident without detailed examination or a long-drawn process of reasoning; an allegedly erroneous view of law is not, by itself, a ground for review.

The Court found that the petitioner’s challenge to the admissibility of Ex. P/1 had already been specifically considered in the first appeal: question 13(b) addressed admissibility, and the appellate judgment discussed the matter in paragraphs 18–19.

The basis of the suit and the related issues had also been considered in paragraphs 21–24 of that judgment.

The review grounds therefore sought reconsideration of matters already decided, rather than identifying new evidence or a patent error.

Applying the restricted scope of review, the Court held that the petitioner’s arguments—including reliance on Sunkari Tirumal Rao v. Penki Aruna Kumar—did not disclose a reviewable ground.

It rejected the review petition, leaving the appellate judgment dated 30 January 2024 undisturbed.