Review jurisdiction is limited to errors apparent on record and cannot be exercised as an appeal in disguise.

The Review Applicants (North Central Railway) filed an application under circulation seeking a review of the Tribunal's order dated 14.01.2026 passed in O.A. No. 206/2020

The applicants contended that the Tribunal failed to consider certain material facts and committed an error apparent on the face of the record

The Tribunal noted that the original order was passed on merits based on the pleadings and that the applicants failed to produce any new or relevant facts that were unavailable at the time of the initial hearing

1. Whether the review applicant established an "error apparent on the face of the record" or discovered "new and important matter or evidence" as required under the Administrative Tribunals Act and the CPC

2. Whether a review application can be maintained for the purpose of re-evaluating the case on merits or as an "appeal in disguise"

Section 22(3)(1) of the Administrative Tribunals Act, 1985, read with Order 47 Rule 1 of the Code of Civil Procedure (CPC), which limits review to cases of discovery of new evidence, errors apparent on the face of the record, or other sufficient reasons

State of West Bengal v. Kamal Sengupta (2008), which established that an error must be self-evident and not one requiring a long process of reasoning

Rajendra Kumar v. Rambhai (2007) regarding the finality of judgments

Lily Thomas v. Union of India (2000), which clarified that the power of review is for the correction of a mistake and not to substitute a view or act as an appeal in disguise

The Tribunal reasoned that its power of review is not synonymous with appellate jurisdiction; it cannot re-hear a matter simply to facilitate a change of opinion on merits

Upon examining the application, the Tribunal found that the applicants merely reiterated facts already presented in the Original Application without identifying any self-evident error in the order dated 14.01.2026

The Tribunal observed that all grounds and facts available on record had already been taken into consideration in the initial decision

As no new evidence was produced that could not have been discovered earlier with due diligence, the application failed to meet the statutory requirements of Order 47 Rule 1 of the CPC

Consequently, the Tribunal dismissed Review Application No. 14 of 2026 on its merits