Review jurisdiction cannot be invoked to reappreciate evidence or correct an erroneous decision.

The applicants, Baj Singh and Dalbir Singh, filed review applications under Order XLVII Rule 1 read with Section 151 of the Code of Civil Procedure, 1908, seeking review of the common judgment dated 17 December 2025 passed in a batch of writ petitions, led by CWP No. 1301 of 2022, including CWP Nos. 15262 of 2022 and 6725 of 2023.

The applicants contended that the judgment under review had not independently considered the peculiar facts and circumstances of their respective cases and that such non-consideration constituted an error apparent on the face of the record.

Applications under Section 5 of the Limitation Act, 1963 were also filed seeking condonation of a delay of 223 days in filing the review applications. The Court condoned the delay in both matters.

Whether the delay of 223 days in filing the review applications should be condoned under Section 5 of the Limitation Act, 1963?

Whether the applicants established any ground under Order XLVII Rule 1 CPC—particularly discovery of new and important matter, error apparent on the face of the record, or any analogous sufficient reason—warranting review of the common judgment dated 17 December 2025?

Whether the review applications could be used to re-argue the merits of the writ petitions or seek fresh appreciation of matters already adjudicated?

The Court applied Section 5 of the Limitation Act, 1963 to condone delay where sufficient grounds were shown.

Review jurisdiction was governed by Order XLVII Rule 1 read with Section 151 CPC, under which review is permissible only upon discovery of new and important matter or evidence that, despite due diligence, was unavailable earlier; an error apparent on the face of the record; or any other sufficient reason analogous to the specified grounds.

Relying on Kamlesh Verma v. Mayawati, 2013 SCC OnLine SC 714, State of Telangana v. Mohd. Abdul Qasim (Died), 2024 INSC 310, Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, (1979) 4 SCC 389, and Parison Devi v. Sumitri Devi, (1997) 8 SCC 715, the Court reiterated that review is not an appeal in disguise, that a mere erroneous decision or the possibility of another view is insufficient, and that an error apparent must be self-evident and not discoverable only through elaborate reasoning.

Re-appreciation of evidence or re-argument on the merits is outside the scope of review jurisdiction.

The Court first accepted the grounds advanced in the applications for condonation and condoned the 223-day delay in filing both review applications.

On merits, however, it held that the applicants’ contention—that the earlier judgment had not sufficiently considered the peculiar facts of their cases—essentially sought reconsideration of the adjudicated issues and a different conclusion on the merits.

Applying the restrictive principles governing review, the Court found no newly discovered material that had been unavailable despite due diligence, nor any patent, self-evident error apparent on the face of the record.

The applicants’ grounds were therefore characterized as grounds of appeal rather than grounds of review. The Court declined to undertake a fresh appreciation of the issues or to sit in appeal over its own judgment.

However, it held that no ground under Order XLVII Rule 1 CPC was established.

Since the applications sought, in substance, to re-argue the writ petitions and obtain a fresh determination on merits, both review applications—RA-CW Nos. 504 and 506 of 2026—were dismissed.

A photocopy of the order was directed to be placed on the file of the connected case.