Review jurisdiction cannot reargue issues already considered absent an error apparent on the record.

The petitioner sought review of the judgment/order dated 11.05.2026 passed in connected proceedings arising from W.P. No. 29965 of 2024 and W.A. No. 423 of 2026.

He alleged that, despite the Bank’s undertaking not to take coercive action against him, a Look Out Circular (“LOC”) had been issued.

He contended that he became aware of the LOC only on 08.09.2024 and therefore could not have challenged it in his earlier writ petitions filed in 2019 and 2020 concerning his classification as a wilful defaulter.

The petitioner further argued that the LOC impaired his right to travel under Article 21 of the Constitution and violated the order dated 09.07.2019 in W.P. No. 12955 of 2019 and the undertaking given by the Bank in W.P. No. 5546 of 2020.

Whether the judgment under review contained an error apparent on the face of the record by failing to consider the alleged issuance of the LOC despite the Bank’s undertaking not to take coercive action

Whether the petitioner’s alleged subsequent knowledge of the LOC on 08.09.2024 justified review, on the ground that the LOC could not have been challenged in the earlier writ proceedings

Whether the issuance of the LOC, allegedly affecting the petitioner’s right to travel under Article 21, warranted reconsideration of the merits in review jurisdiction

Whether the review petition could be used to re-agitate issues already considered in the earlier proceedings

Review jurisdiction is limited and cannot be exercised as an appeal or as a means of rehearing the matter on merits.

A review is maintainable only where there is an error apparent on the face of the record, a patent mistake, or manifest injustice; mere possibility of another view or dissatisfaction with the merits is insufficient.

The Court relied on Northern India Caterers (India) Ltd. v. Lt. Governor of Delhi, (1980) 2 SCC 167, which holds that review is not permissible merely for rehearing a case or because another view is possible.

Parsoni Devi v. State of Bihar, (2004) 1 SCC 632, which reiterates that review cannot be sought for a subsequent change in law or reconsideration of issues already decided.

The Court held that the alleged LOC, the Bank’s undertaking, the petitioner’s claimed date of knowledge, and the effect of the earlier orders were all matters arising from the existing record and had been considered in the proceedings under review.

It further found that the argument that the LOC could not earlier have been challenged had also been addressed after considering W.P. Nos. 5546 of 2020 and 12955 of 2019 and the connected proceedings culminating in W.A. No. 423 of 2026; consequently, no separate relief survived for consideration.

The contention that the LOC was coercive and infringed the right to travel under Article 21 was viewed as an attempt to obtain reconsideration of the merits, which is outside the narrow scope of review jurisdiction.

Since the petitioner merely repeated grounds already considered and identified no patent mistake or manifest error, the requirements for review were not satisfied.

It held that no error apparent on the face of the record, patent mistake, or manifest injustice had been demonstrated; the petitioner’s grounds amounted to an attempt to re-agitate and rehear issues already decided.

Accordingly, Review Petition No. 1201 of 2026 was dismissed.