Review jurisdiction cannot be invoked to rehear a matter absent patent error on the record.

The petitioner sought review of the order dated 31 August 2026 in W.P. No. 15139 of 2024.

He submitted that he had not placed before the Court the order dated 16 July 2024 in W.A. No. 1510 of 2024, and that its omission had prevented the Court from granting back wages.

He claimed entitlement to back wages from 7 November 2020.

The State opposed the petition, contending that the review jurisdiction was limited and that no error apparent on the face of the record had been shown.

Whether the petitioner’s failure to submit the order dated 16 July 2024 in W.A. No. 1510 of 2024 disclosed a ground for review of the order in W.P. No. 15139 of 2024.

Whether the review jurisdiction could be invoked to reconsider the petitioner’s claim for back wages in the absence of an error apparent on the face of the record.

Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure permit review on discovery of new and important matter or evidence that, despite due diligence, was not available or could not be produced; an error apparent on the face of the record; or another sufficient reason.

In Kamlesh Verma v. Mayawati, (2013) 8 SCC 320, the Supreme Court summarised the grounds on which review may, and may not, be entertained.

State of West Bengal v. Kamal Sengupta, (2008) 8 SCC 612, explains that an apparent error must be prima facie visible and not require detailed examination; an erroneous view of law is not itself a review ground.

Col. Avatar Singh Sekhon v. Union of India, 1980 Supp SCC 562, and Parsion Devi v. Sumitri Devi, (1997) 8 SCC 715, affirm that review is not an appeal in disguise and that an error requiring reasoning to detect is not an error apparent on the face of the record.

Applying these principles, the Court found no apparent error or other basis warranting review.

The petitioner’s reliance on the unsubmitted appellate order and renewed claim to back wages did not demonstrate a patent error in the earlier order.

Review could not be used to rehear the matter or take a different view on the same facts, and the Court found no ground to interfere with its prior decision.

It dismissed the review petition as devoid of merit.