Review jurisdiction cannot be used for fresh adjudication absent an error apparent on the record.

The applicants sought review of the Tribunal’s order dated 2 May 2025, which had directed the respondents to consider and grant them benefits similar to those granted by the Ahmedabad Bench, if they were found eligible, within three months.

They contended that the original order did not quash the impugned order and that the respondents were therefore refusing to implement it.

The Tribunal considered whether this ground justified review.

1. Whether the original order’s failure to quash the impugned order constituted an apparent error warranting review

2. Whether the review application could be used to obtain a fresh adjudication or enlargement of the relief granted in the original application

Under Section 22(3)(f) of the Administrative Tribunals Act, 1985, the Tribunal’s review power is analogous to a civil court’s power under Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure.

Review is confined to the grounds in Order 47 Rule 1, including an error apparent on the face of the record; it is not an appeal or an opportunity for rehearing on the merits.

An error requiring lengthy reasoning to establish is not apparent.

The Tribunal relied on Ajit Kumar Rath v. State of Orissa, (1999) 9 SCC 596; Meera Bhanja v. Nirmala Kumari Choudhury, (1995) 1 SCC 170; Union of India v. Tarit Ranjan Das, 2004 SCC (L&S) 160; and State of West Bengal v. Kamal Sengupta, (2008) 2 SCC (L&S) 735.

The original order expressly required the respondents to consider and grant similar benefits to the applicants, subject to eligibility, within the stipulated period.

The Tribunal held that the absence of an express direction quashing the impugned order did not, by itself, establish an apparent error warranting review.

The applicants’ request would instead require reconsideration of the original dispute or an enlargement of the relief, which falls outside the limited review jurisdiction.

As no qualifying error apparent on the face of the record was shown, the review application could not succeed.

No order as to costs was made, and any pending miscellaneous applications were disposed of.