Review jurisdiction cannot be used to re-agitate merits or seek rehearing of issues already decided.

The review petitioner, South Eastern Coalfields Limited (SECL), sought a review of the order dated 27.01.2026 passed in WPC No. 6013/2024

In the original writ petition, Respondent No. 1 (Ishwarilal Sahu) challenged SECL's refusal to grant employment following the acquisition of his land in 2009

The court had previously set aside SECL’s rejection, holding that the right to employment accrued under the State Rehabilitation Policy of 2007 at the time of acquisition and could not be defeated by subsequent internal guidelines or the Coal India Limited (CIL) policy

SECL moved for review on grounds that the court ignored material facts such as artificial subdivision of land to multiply claims, non-fulfillment of the three-year ownership rule, and the fact that one family member had already received employment

1. Whether the judgment dated 27.01.2026 suffered from an error apparent on the face of the record warranting review under the High Court's review jurisdiction

2. Whether the Court can reconsider the merits of the case, including the applicability of specific CIL policies and factual disputes regarding land subdivision, within a review petition

The Court applied the narrow doctrine of Review Jurisdiction, emphasizing that a review is not an "appeal in disguise"

It relied on established precedents including Meera Bhanjan v. Smt. Nirmal Kumar Chowdhary and Lily Thomas v. Union of India, which hold that a review is only maintainable if there is a patent, self-evident error on the face of the record or discovery of new material that could not be produced earlier despite due diligence

Substantively, the court reiterated that rehabilitation rights are a logical corollary of Article 21 of the Constitution of India and must be governed by the policy prevalent at the time of land acquisition

The Court observed that SECL’s submissions—regarding land fragmentation, the three-year ownership condition, and prior employment—were essentially attempts to reagitate and reopen findings already settled in the original judgment

The Court noted that it had previously determined that the 2009 acquisition was a distinct proceeding from earlier ones and that the land losers' rights were anchored in the State Rehabilitation Policy of 2007

The Court reasoned that dissatisfaction with a legal conclusion or a desire to substitute one possible view for another does not constitute a "manifest error"

Since the review petitioners failed to show any patent error or new evidence, but instead argued the merits of the controversy, the application fell outside the scope of review jurisdiction

The Court affirmed that the earlier judgment correctly identified the 2009 acquisition as an independent cause of action and that the review petitioners were attempting an impermissible fresh argument of the entire case

The original direction to consider the respondent's claim for rehabilitation under the 2007 Policy within 45 days stands