Review jurisdiction cannot be invoked to re-adjudicate merits or introduce grounds of appeal.

The applicants filed Review Application No. 152 of 2026 under Section 114 of the Code of Civil Procedure, 1908, seeking review of the Division Bench’s order dated 8 July 2025 in W.A. No. 810 of 2024.

The applicants contended that the earlier judgment had not been considered in its proper perspective and that certain other judgments, which were not produced during the final hearing of the writ appeal, ought to have been considered.

The respondents included the Principal Secretary, Municipal Administration and Water Supplies Department, the Commissioner of the Greater Chennai City Corporation, and other concerned parties.

Whether the grounds raised by the applicants disclosed an error apparent on the face of the record warranting review under Section 114 of the Code of Civil Procedure, 1908?

Whether the review jurisdiction could be invoked to reconsider the merits of the writ appeal or to rely upon judgments that had not been produced at the original hearing?

The Court applied Section 114 of the Code of Civil Procedure, 1908, governing the power of review.

The Court reiterated that review jurisdiction is limited and may be exercised only where an error apparent on the face of the record or another legally recognised ground for review is established.

It further held that review proceedings cannot be used as a substitute for an appeal, for re-adjudication of the merits, or for expanding the scope of the original proceedings to consider arguments and materials not previously relied upon.

The Court examined the grounds in the review application and found that the applicants were essentially seeking reconsideration of the merits of the judgment rendered in the writ appeal.

The contention that the earlier decision had not been properly appreciated, together with the reliance on judgments not produced at the original hearing, constituted grounds of appeal rather than an identifiable error apparent on the face of the record.

Since review jurisdiction does not permit a rehearing or re-adjudication of the issues, the applicants failed to satisfy the threshold required for interference under Section 114 CPC.

Accordingly, Review Application No. 152 of 2026 was dismissed, the connected CMP No. 19867 of 2026 was closed, and there was no order as to costs.