Review jurisdiction cannot be used as an appeal in disguise to revisit merits or substitute findings.

The petitioner filed a review petition seeking to recall an order dated February 19, 2026, passed in First Appeal No. 656/2009.

In that appeal, the High Court had remanded the matter to the Additional District Judge, Rehli, to appoint a new Board of Trustees.

The petitioner argued the original order was passed ex-parte and that the respondents lacked the legal standing to interfere in trust management as they were not members of the relevant community or legal heirs of previous trustees.

The petitioner further alleged that the respondents were using the court's order to forcefully take possession of trust property.

1. Whether the petitioner established sufficient grounds for the court to exercise its review jurisdiction to recall or reheard the matter based on subsequent facts.

2. Whether there exists an error apparent on the face of the record that justifies a modification of the prior judgment under the Code of Civil Procedure.

The court applied the principles governing review jurisdiction under Section 114 and Order 47 Rule 1 of the Code of Civil Procedure (CPC).

It specifically relied on the binding precedent of Kamlesh Verma v. Mayawati (2013) 8 SCC 320, which dictates that a review is not an appeal in disguise and cannot be maintained for minor mistakes, a mere possibility of two views, or the re-appreciation of evidence.

The doctrine establishes that review is only permissible for patent errors manifest on the face of the record.

The court reasoned that the scope of review is strictly limited and does not allow the court to revisit the merits of a case or re-evaluate evidence already adjudicated in the appellate stage.

Upon perusing the record, the court found that the petitioner failed to identify any manifest error or "patent error" in the original order that would meet the high threshold for review.

Regarding the petitioner's concerns about the respondents' interference with the property, the court determined that the existing order merely remitted the case for the appointment of trustees and did not grant the respondents a right to forceful possession.

Consequently, the court found that the arguments presented were an attempt to re-argue the case rather than pointing out a procedural or legal oversight apparent from the record.

The petition was dismissed. However, the court clarified that the petitioner remains at liberty to move the appropriate application before the Civil Court in accordance with the law regarding the trust management and possession issues.