Review jurisdiction cannot introduce unpleaded grounds or serve as an appeal in disguise.

The applicants sought review under Order XLVII Rule 1 CPC of the judgment dated 23 December 2025 passed in CWP No.31045 of 2025.

They contended that notifications dated 14 October 2019 and 21 October 2019 had not been properly implemented and that certain posts reserved for Ex-Servicemen and sportspersons remained vacant.

According to them, the Corporation ought to have operated the waiting list against those vacancies.

The Corporation opposed the review, arguing that this ground had neither been pleaded in the writ petition nor raised in the original representation.

It further submitted that the petitioners approached the Court only on 24 June 2025, approximately three years after the 2022 advertisement, and that the vacancies had subsequently been carried forward in later advertisements issued in 2023 and 2025.

The Court first condoned the 13-day delay in filing the review application under Section 5 of the Limitation Act, 1963.

It also allowed the application to place the order dated 1 August 2026 and the notifications dated 14 October 2019 and 21 October 2019 on record as Annexures P-7 to P-9, subject to just exceptions.

Whether the review application disclosed discovery of new and important matter, an error apparent on the face of the record, or any other sufficient reason under Order XLVII Rule 1 CPC?

Whether the petitioners could introduce, at the review stage, the contention that unfilled posts in the Ex-Servicemen and sportsperson categories required operation of the waiting list, despite that ground not having been pleaded in the writ petition or raised earlier?

Whether the review could be used to re-argue the case or seek reconsideration of the original judgment through a different counsel?

The Court applied Order XLVII Rule 1 CPC, under which review is maintainable only upon 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 those grounds.

An error apparent must be self-evident and not one requiring a process of reasoning; review cannot operate as an appeal or permit re-appreciation of evidence or re-argument on merits.

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. Sandur Manganese & Iron Ores Ltd.; Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, (1979) 4 SCC 389; Parison Devi v. Sumitri Devi, (1997) 8 SCC 715; and S. Murali Sundaram v. Jothibai Kannan.

The Court further applied the pleading principle stated in State of Orissa v. Mamata Mohanty, (2011) 3 SCC 436, that relief cannot ordinarily be granted on grounds outside the pleadings.

The Court relied on Tamil Nadu Electricity Board v. N. Raju Reddiar, (1997) 9 SCC 736, against using review through a different counsel to re-argue a concluded matter.

The Court held that the petitioners’ contention regarding unfilled reserved posts and operation of the waiting list was a new ground that had not formed part of the original writ proceedings or representation.

The documents subsequently produced did not establish any self-evident error in the judgment dated 23 December 2025, nor did the petitioners demonstrate that the alleged new material was unavailable despite due diligence at the time of the original hearing.

Permitting the petitioners to rely on the new contention would improperly introduce a new case, fill omissions in the pleadings, and require reconsideration of the merits, which was impermissible in review jurisdiction.

The Court also treated the petitioners’ delay in approaching the Court as independently weakening the claim.

Re-argument through a different counsel could not enlarge the limited scope of review.

Although the 13-day delay was condoned and the additional documents were taken on record, the review application was dismissed.

Any pending miscellaneous application was also disposed of accordingly.