Review jurisdiction cannot introduce fresh pleadings or reargue merits absent an error apparent on the record.

The applicant challenged the Staff Selection Commission’s final selection list dated 06.07.2018 for the post of Assistant Archivist pursuant to Advertisement No. ER-02/2015, alleging that ineligible candidates had been selected and seeking investigation, quashing of the selection list, and her appointment with consequential benefits.

The Tribunal dismissed the original application on 08.04.2025, holding that the applicant had secured fewer marks than the last selected candidate in her category.

The applicant challenged that order before the Delhi High Court, which permitted withdrawal of the writ petition with liberty to file a review, particularly regarding the alleged ineligibility of Shri Shivbhakte Prakash Laxman.

In the Review Application, the applicant contended that Laxman had initially appeared in the rejected list for want of essential qualification but was subsequently permitted to participate in the selection process and was selected.

The respondents argued that the review application introduced fresh pleadings and sought a rehearing on merits rather than correction of any apparent error.

Whether the order dated 08.04.2025 contained an error apparent on the face of the record warranting review or recall of the dismissal of the original application.

Whether the applicant could, at the review stage, introduce detailed factual allegations concerning the alleged ineligibility and subsequent selection of Shri Shivbhakte Prakash Laxman, without having impleaded him as a necessary party in the original proceedings.

Whether the applicant’s allegation regarding the selection of an allegedly ineligible candidate displaced the undisputed finding that she had obtained fewer marks than the last selected candidate in her category.

The Tribunal applied the settled principles governing review jurisdiction: review is confined to correction of an error apparent on the face of the record and cannot be used as an appellate rehearing, for introducing fresh pleadings or evidence, or for rearguing the original case.

It further applied the procedural principle that a person whose selection or rights are directly impugned must ordinarily be impleaded as a necessary party and given an opportunity to defend the case.

The Tribunal also relied on the principle that a review applicant must demonstrate an error in the reasoning or record underlying the impugned order; merely raising new allegations or disputing the merits of the decision is insufficient.

The Tribunal found that the detailed allegations concerning Laxman’s initial rejection, subsequent submission of documents, and participation in the interview were not part of the original pleadings in the OA; the OA contained only a passing reference to seven allegedly ineligible candidates.

The applicant had also failed to implead Laxman as a necessary party, despite directly challenging the validity of his selection.

Accordingly, consideration of those allegations would require a fresh factual inquiry and would amount to expanding and improving the original case at the review stage, which exceeded the limited scope of review jurisdiction.

Further, the applicant did not controvert the foundational factual finding that she had obtained fewer marks than the last selected candidate in the relevant category. The Tribunal therefore held that no apparent error existed in the original dismissal order.

It held that the Review Application was an attempt to reargue the original matter and introduce fresh factual allegations concerning a non-impleaded selected candidate, rather than demonstrate an error apparent on the face of the record.

RA No. 162/2025 was accordingly dismissed for want of merit; there was no order as to costs, and any pending miscellaneous applications were also disposed of.