Review jurisdiction cannot be invoked to reargue matters or reassess evidence absent patent error.

The applicants/petitioners sought review of the common judgment dated 17 December 2025 passed by the High Court in a batch of writ petitions, led by CWP No.1301 of 2022, including CWP Nos.4327 of 2023 and 11503 of 2022.

The review applications were filed with a delay of 223 days. Applications under Section 5 of the Limitation Act, 1963 read with Section 151 CPC were consequently filed for condonation of delay.

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.

The Court condoned the delay of 223 days in both review applications.

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

2. Whether the applicants established any ground under Order XLVII Rule 1 CPC, including discovery of new and important matter, an error apparent on the face of the record, or any other sufficient reason, warranting review of the judgment dated 17 December 2025?

3. Whether the review applications could be used to re-argue the merits of the writ petitions or seek a fresh appreciation of the evidence and issues already adjudicated?

The Court applied Section 5 of the Limitation Act, 1963, permitting condonation of delay upon sufficient cause, and Section 151 CPC, recognising the Court’s inherent procedural powers.

Review jurisdiction was governed by Order XLVII Rule 1 CPC, under which review is permissible only upon discovery of new and important matter or evidence that could not, despite due diligence, have been produced 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, the Court held that review is not an appeal in disguise, cannot be used for re-appreciation of evidence or repetition of old arguments, and is unavailable merely because two views are possible.

The Court also relied on State of Telangana v. Mohd. Abdul Qasim (Died), 2024 INSC 310, which held that the error must be self-evident, grave and apparent on a cursory examination, and that review is an exceptional and restrictive jurisdiction.

The principles in Union of India v. Sandur Manganese & Iron Ores Ltd., Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, Parison Devi v. Sumitri Devi and S. Murali Sundaram v. Jothibai Kannan were also applied against reopening a concluded decision merely on the ground that it was allegedly erroneous on merits.