Review jurisdiction cannot reopen consequential-benefit directions absent an error apparent on the record.

In W.P. No. 13552/2025, the High Court set aside orders of the disciplinary, appellate and revisional authorities and remanded the matter for fresh consideration.

The petitioner sought review, confined to paragraphs 16(vi) and 16(vii) of that order. He contended that he had received no pensionary or other retiral benefits and that the direction applying “No Work No Pay” improperly foreclosed his claims to salary, back wages and consequential benefits during the intervening period.

The respondents opposed review, arguing that no error apparent had been shown.

Whether the directions concerning “No Work No Pay” and the petitioner’s claims for intervening-period benefits disclosed an error apparent warranting review

Whether the petitioner’s assertion that he had received no retiral benefits, or his reliance on *Rampal Singh*, justified review of the earlier order

Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure permit review on discovery of new and important matter or evidence despite due diligence, an error apparent on the face of the record, or another sufficient reason.

Under *Kamlesh Verma v. Mayawati*, (2013) 8 SCC 320, and *State of West Bengal v. Kamal Sengupta*, (2008) 8 SCC 612, review is not an appeal in disguise; an apparent error must be prima facie visible and not require detailed examination.

*Col. Avatar Singh Sekhon v. Union of India*, 1980 Supp SCC 562, and *Parsion Devi v. Sumitri Devi*, (1997) 8 SCC 715, establish that review is justified only for a patent, material error, not an allegedly erroneous decision requiring reconsideration.

The Court held that the petitioner’s challenge to “No Work No Pay” sought reconsideration of a direction already considered in the writ proceedings; the remand itself did not establish a ground for review on the merits.

His assertion that he had received no retiral benefits raised a factual or consequential issue for implementation, to be addressed by the competent authority in accordance with law, rather than by reopening the order in review.

Reliance on *Rampal Singh* likewise did not demonstrate an apparent error, and the petitioner remained at liberty to raise permissible claims before the competent authority.

It dismissed the review petition as devoid of merit, without foreclosing the petitioner from raising permissible claims and contentions before the competent authority in accordance with law.