### Review Jurisdiction Cannot Be Invoked to Adjudicate Disputed Factual Questions or Adverse Possession Claims in Writ Proceedings

The petitioners sought a review of the judgment dated 19.05.2023, which dismissed Letters Patent Appeal (L.P.A.) No. 212 of 2019.

The underlying dispute involved orders passed by the Commissioner, Settlement Officer, and Assistant Settlement Officer regarding land records.

The petitioners contended that the L.P.A. was dismissed on the erroneous premise that there was no specific prayer to challenge the revenue orders dated 19.02.2007 and 25.06.1987, despite such prayers being quoted in the judgment.

Respondents argued that the prayers were vague and that the dismissal was based on the presence of complex factual disputes—such as claims of adverse possession and challenges to the lineage of Lakhpati Singh—which could not be adjudicated under writ jurisdiction.

1. Whether there exists an error apparent on the face of the record regarding the absence of a specific prayer clause that warrants the exercise of review jurisdiction.

2. Whether factual disputes involving adverse possession and identity (genealogy) can be conclusively determined by Court exercising extraordinary jurisdiction under Article 226 of the Constitution.

The Court applied the principles governing review jurisdiction, which require the identification of an "error apparent on the face of the record" for interference.

The Court relied on the jurisdictional limits of Article 226 of the Constitution of India, holding that extraordinary writ jurisdiction is not the appropriate forum for deciding complex factual disputes, such as claims of adverse possession or disputed questions of inheritance and identity.

The Court found that while the prayer clause in the original writ petition was "most confusing," the observation regarding the absence of a specific prayer was not the sole or primary ground for dismissing the L.P.A.

The Division Bench emphasized that the "weightier grounds" for dismissal remained valid: the case involved disputed facts regarding whether Lakhpati Singh was an impostor and the validity of the petitioners' claim of adverse possession.

The Court reasoned that Revenue Authorities and Writ Courts cannot conclusively decide such factual matters.

It noted that the Single Judge had appropriately protected the petitioners' rights by observing that if eviction proceedings were initiated, the petitioners could establish their claim of adverse possession independently of the observations in the revenue order dated 19.02.2007.

The bench determined that no error apparent on the face of the record existed because the core of the dismissal rested on the nature of the dispute rather than a clerical omission of the prayer.

It affirmed that the dismissal of the L.P.A. was justified as the disputes were factual in nature and the petitioners had already been granted the liberty to raise their defense of adverse possession in appropriate future eviction proceedings.

No costs were awarded.