Review jurisdiction cannot revisit a delay-condonation order absent an error apparent.

The petitioner filed a review application under Section 114 and Order XLVII Rules 1 and 2 of the Code of Civil Procedure, 1908, challenging the Madras High Court’s order dated 17 June 2026 in CMP No. 12776 of 2026 in W.A. No. 1743 of 2026, by which a delay of 227 days in filing an intra-Court appeal by Tata AIG General Insurance Company Ltd. had been condoned.

The respondent had explained that it became aware of the order only when the petitioner initiated proceedings in January 2026 and that time was thereafter required for collating records, obtaining internal approvals, and securing legal advice.

The petitioner had opposed the condonation application, but the Court accepted the explanation and condoned the delay.

1. Whether the order condoning the respondent’s delay of 227 days disclosed an error apparent on the face of the record warranting review under Section 114 and Order XLVII CPC.

2. Whether the reasons stated by the respondent constituted sufficient cause for condoning the delay in filing the intra-Court appeal.

The Court applied Section 114 and Order XLVII Rules 1 and 2 CPC, under which review is available only on established grounds such as discovery of new evidence, an error apparent on the face of the record, or another sufficient reason.

The Court further applied the principle that delay may be condoned where sufficient cause is shown and that a reasonable degree of latitude may be afforded in appropriate cases; however, an enormous delay would ordinarily not be condoned without a valid explanation.

The Court examined the explanation contained in the respondent’s affidavit and found that the respondent had stated that it lacked knowledge of the relevant order until January 2026 and had acted thereafter with promptitude, although internal administrative processes, record collection, approvals, and legal advice consumed additional time.

Since the petitioner’s objections had already been considered in the original condonation proceedings and were found insufficient to defeat the application, the Court held that the decision to condone the 227-day delay did not suffer from any error apparent on the face of the record.

The review jurisdiction could not therefore be used merely to re-agitate the petitioner’s opposition to condonation.

Accordingly, Review Application No. 156 of 2026 was dismissed, with no order as to costs.