Review jurisdiction cannot be exercised to re-argue or re-appreciate merits under the guise of appeal.

The petitioner filed Civil Suit No. 311/2023 for specific performance of an agreement to sell dated 18.01.2022 against respondents No. 2 to 14.

Subsequently, the respondents allegedly executed a second agreement with respondent No. 1 and instituted a second suit (No. 103/2024), suppressing the first suit's existence.

In the second suit, a compromise application under Order XXIII Rule 3 CPC was filed. The High Court, in M.P. No. 6032/2024 (dated 11.11.2025), directed the Trial Court to record this compromise and pass a conditional decree subject to statutory permissions.

The petitioner filed this review petition alleging collusion and error apparent on the record, arguing that the subsequent suit and decree defeat his prior rights.

1. Whether there exists an error apparent on the face of the record or sufficient grounds under Order 47 Rule 1 of the CPC to warrant a review of the order dated 11.11.2025.

2. Whether the petitioner’s claims of collusion and deceit between the respondents constitute a valid ground for review jurisdiction as opposed to appellate jurisdiction.

Order 47 Rule 1 of the Code of Civil Procedure (CPC), which limits review to the discovery of new evidence, errors apparent on the face of the record, or other analogous sufficient reasons.

Asharfi Devi v. State of U.P. (2019) to establish that a review is not an "appeal in disguise" and errors must be self-evident without long-drawn reasoning.

Kamlesh Verma v. Mayawati (2013) regarding the impermissibility of re-arguing merits.

Lily Thomas v. Union of India (2000) on the strict parameters of review.

Malleeswari v. K. Suguna (2025) which underscores that a review court does not sit in appeal over its own order.

The court examined the petitioner’s contention that the second suit was a result of collusion intended to bypass the petitioner’s prior agreement. However, the court found that these arguments were essentially an attempt to re-litigate the merits of the case already decided in Miscellaneous Petition No. 6032/2024.

Applying the cited precedents, the court reasoned that an "error apparent" must be strike-evident and not one requiring a complex process of reasoning or re-appreciation of evidence.

Since the petitioner’s grounds required a reconsideration of factual findings regarding the validity of the second agreement and the alleged deceit, the court determined that such grievances fall within appellate territory rather than the narrow, circumscribed scope of review jurisdiction.

The court concluded that the petitioner failed to demonstrate any patent error or discover new evidence that met the legal threshold for review, noting that the contentions raised were merely placeholders for a rehearing. No order as to costs was made.