Review jurisdiction cannot re-adjudicate merits absent an error apparent on the record.

The petitioners sought review of the common order dated 20 August 2026 in W.A. Nos. 1990–1994 of 2026; Review Application Nos. 248 and 250 of 2026 concerned W.A. Nos. 1990 and 1994, respectively

They contended that the Court had not considered a similar Division Bench decision affirmed by the Supreme Court, other Supreme Court judgments, and the resulting disparity among employees

The Transport Corporation opposed review, submitting that the original order had considered G.O. Ms. No. 330 dated 31 August 2018 and had left employees free to approach the competent authority regarding errors in pay fixation

1. Whether the alleged failure to consider precedent and other grounds established an error apparent on the face of the record warranting review under Order 47 Rule 1 CPC

2. Whether the review petitions could be used to reargue the merits of the pay-fixation dispute

Order 47 Rule 1 CPC permits review on discovery of new and important matter or evidence, an error apparent on the face of the record, or another sufficient reason analogous to the specified grounds

An error that requires reasoning to identify is not an error apparent, and review cannot operate as an appeal or substitute one view for another

The Court relied on Kamlesh Verma v. Mayawati, (2013) 8 SCC 320, which summarises the grounds on which review is maintainable and those on which it is not

It also referred to Chhajju Ram v. Neki, Moran Mar Basselios Catholicos v. Most Rev. Mar Poulose Athanasius, and Union of India v. Sandur Manganese & Iron Ores Ltd. on the meaning of “any other sufficient reason”

The Court treated the petitioners’ contentions—including the asserted omission of precedent and alleged disparity—as grounds directed to the merits of the earlier decision, rather than as proof of a patent error in its record

It noted that the original order had considered the scope of G.O. Ms. No. 330, including eligibility and the multiplier factor, and had provided liberty to approach the competent authority over any pay-fixation error

Since reconsidering the petitioners’ arguments would amount to re-adjudication, the Court found no basis to exercise review jurisdiction

It dismissed both review petitions without costs