Review jurisdiction cannot be used to reargue matters or correct alleged errors on merits.

The applicants sought review under Article 226 of the Constitution of India, read with Order XLVII Rules 1 and 2 and Section 114 of the Code of Civil Procedure, 1908, of the common judgment dated 03.09.2025 passed in a batch of writ petitions led by Hans Raj and others v. Pepsu Road Transport Corporation and another.

In that judgment, the Court had held that the applicants completed the prescribed probationary period on 03.06.2018 and were deemed to have been confirmed thereafter in accordance with the applicable Regulations and the decision in Dalbir Singh and others v. Pepsu Road Transport Corporation and another, CWP No. 8240 of 2008.

The applicants alleged that, despite this finding, the respondents’ orders dated 03.06.2026 regularized their services prospectively from 25.10.2025 and again placed them on probation.

The Court heard the parties and examined the record.

Whether the applicants established a ground for review under Order XLVII Rule 1 CPC, particularly an error apparent on the face of the record, in relation to the respondents’ prospective regularization orders and re-imposition of probation.

Whether the review applications could be used to re-argue the merits of the original judgment or obtain a different conclusion as though in an appeal.

Whether the applicants were entitled to a direction treating them as regular employees from 03.06.2018 with consequential benefits.

The Court applied Order XLVII Rule 1 CPC, under which review is maintainable only on discovery of new and important matter or evidence despite due diligence, an error apparent on the face of the record, or another sufficient reason analogous to the specified grounds.

An error apparent must be self-evident, patent, and discernible without a lengthy process of reasoning; a review cannot operate as an appeal or permit re-appreciation of evidence or reconsideration of an allegedly erroneous decision.

The Court relied on Kamlesh Verma v. Mayawati, 2013 SCC OnLine SC 714, State of Telangana v. Mohd. Abdul Qasim (Died), 2024 INSC 310, Union of India v. Daljit Singh, RA-CW No. 167 of 2026, and the principles stated in Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, (1979) 4 SCC 389, and Parison Devi v. Sumitri Devi, (1997) 8 SCC 715.

A decision cannot be reviewed merely because another view is possible or because the applicant considers the decision erroneous on merits.

The Court held that the applicants’ challenge was, in substance, directed at the implementation and legal effect of the earlier judgment and sought a further direction for retrospective regularization and consequential benefits.

Determining whether the respondents’ orders correctly applied the earlier findings would require reconsideration of the merits and potentially a fresh evaluation of the issues already adjudicated.

Such a re-examination falls outside the limited scope of review jurisdiction.

The applicants did not demonstrate any newly discovered material unavailable despite due diligence, nor did they identify a patent and self-evident error in the judgment dated 03.09.2025.

The Court therefore declined to exercise review jurisdiction as an appellate power or to re-hear the matter under the guise of review.

All three review applications—RA-CW Nos. 518, 532, and 533 of 2026—were dismissed, and all pending miscellaneous applications were disposed of accordingly.