Review jurisdiction cannot correct an allegedly erroneous decision or substitute the Court’s view.

Opposite Party Nos. 1–3 had filed an objection under Section 9(3) of the Orissa Consolidation of Holdings and Prevention of Fragmentation of Land Act, challenging the entries in the relevant settlement records and the note of possession recorded in favour of the review petitioner’s father.

The Consolidation Officer allowed the objection on 29 June 1999. The petitioner’s appeal under Section 12 and revision under Section 36 of the Act were dismissed on 9 May 2000 and thereafter by the Revisional Court, respectively.

The petitioner then challenged those orders in W.P.(C) No. 3619 of 2012, which was dismissed by the High Court on 24 March 2023.

The present application sought review of that judgment under Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure, alleging errors apparent on the face of the record and non-consideration of the petitioner’s grounds and legal submissions.

Whether the judgment dismissing the writ petition disclosed an error apparent on the face of the record warranting review under Section 114 read with Order 47 Rule 1 CPC.

Whether the alleged non-consideration of the petitioner’s grounds and the contention that consolidation authorities lacked jurisdiction to determine Sikim tenancy justified review of the earlier judgment.

Whether the review petition could be used to re-agitate the merits of the writ petition or substitute the earlier view of the Court.

The Court applied Section 114 and Order 47 Rule 1 CPC, under which review is confined to discovery of new and important matter or evidence, an error apparent on the face of the record, or another sufficient reason; review is not an appellate rehearing.

The Court relied on Malleeswari v. K. Suguna, 2025 SCC OnLine SC 1927, for the principles that review is distinct from appellate jurisdiction, cannot be used to correct every erroneous decision, and cannot substitute one possible view for another.

It also relied on Sow Chandra Kante v. Sk. Habib, (1975) 1 SCC 674, which holds that review is justified only for a glaring omission, patent mistake, or similarly grave error, and not for repetition of previously argued grounds.

The Court further applied the principle that concurrent findings of fact by statutory authorities are not ordinarily interfered with in certiorari jurisdiction.

The Court found that the Consolidation Officer, appellate authority, and Revisional Court had concurrently rejected the petitioner’s claim on merits, and that such findings did not warrant routine interference in writ jurisdiction.

It held that the earlier judgment had considered the relevant facts, the applicable law, and the authorities cited by the parties.

Although the petitioner alleged that his specific writ grounds had not been separately addressed, the Court noted that those grounds had been reproduced in the earlier judgment and that the Single Judge had given sufficient reasons for declining interference.

The contention that consolidation authorities lacked jurisdiction to decide rights, title, and interest was also rejected because the earlier judgment had held that those authorities, exercising powers analogous to a civil court, possessed such jurisdiction.

The petitioner’s attempt to introduce or re-argue additional grounds was impermissible, particularly where those grounds had not been urged earlier.

The Court therefore concluded that the review petition sought a reconsideration and substitution of the earlier judicial view, which would amount to an appeal in disguise rather than correction of an apparent error.

The review application was accordingly dismissed, and the judgment dated 24 March 2023 dismissing W.P.(C) No. 3619 of 2012 was left undisturbed.