Madhya Pradesh High Court
Civil Procedure and EvidenceEmployment and Labour Law

Review jurisdiction cannot be used to reargue a matter or substitute a different view.

Municipal Corporation Jabalput vs Sushila Shukla

Madhya Pradesh High CourtJUDGMENT: October 16, 20262 MIN READSOURCE JUDGMENT
Review jurisdiction cannot be used to reargue a matter or substitute a different view.. Municipal Corporation Jabalput vs Sushila Shukla. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Municipal Corporation sought review or recall of the common order dated 14 August 2024, passed in a batch of writ appeals that included W.A. No. 461 of 2018.

Source reference: para. 1

Its counsel acknowledged that the same issue had been considered and the review petitions dismissed in R.P. No. 2473 of 2025 and connected cases by an order dated 13 July 2026.

Source reference: para. 2

The earlier order addressed the Corporation’s challenge to the status of long-serving daily-wage workers while continuing to take their services, and directed consideration of eligible workers under the State’s Vinaymitikaran Policy dated 10 June 2017.

Source reference: para. 3
02

Issues

1. Whether the Corporation established a ground warranting review or recall of the common order dated 14 August 2024.

Source reference: para. 1–2

2. Whether the review petition was governed by the decision in R.P. No. 2473 of 2025 and connected cases.

Source reference: para. 2, 5–6
03

Law Applied

Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure limits review to grounds such as discovery of new and important evidence despite due diligence, an error apparent on the face of the record, or another sufficient reason.

Source reference: para. 3

An error must be self-evident and not require lengthy reasoning; review is not an appeal in disguise and cannot be used merely to substitute one view for another.

Source reference: para. 3

The earlier decision also directed consideration of the relevant daily wagers under the State’s Vinaymitikaran Policy dated 10 June 2017.

Source reference: para. 3
04

Reasoning

The Court treated the dispute as squarely covered by its decision in R.P. No. 2473 of 2025 and connected cases.

Source reference: para. 2, 5

The petitioner’s counsel acknowledged that the same issue had already been decided, and the Court identified no basis to depart from that ruling or to grant review.

Source reference: para. 2, 5

It therefore applied the earlier decision mutatis mutandis to the present petition.

Source reference: para. 6
05

Holding

The Court dismissed the review petition.

The Court directed that the order dated 13 July 2026 in R.P. No. 2473 of 2025 and connected cases apply mutatis mutandis.

Source reference: para. 6
06

Acts & Sections Cited

4 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Code of Civil Procedure, 19084

Madhya Pradesh High Court

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Municipal Corporation JabalputvsSushila Shukla

Madhya Pradesh High Court · October 16, 2026

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