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

The petitioners filed a review petition seeking to set aside the judgment dated 23.02.2026 passed in Second Appeal No. 204 of 2014, which had dismissed their appeal

The petitioners contended that the court erred by deciding the issue of limitation based solely on oral evidence, asserting that their possession of the suit land since 1951-52 made the 1989 suit time-barred

They further argued that a 1962 dispute between the parties was not properly considered during the Second Appeal

The court reviewed the record to determine if these grounds met the statutory requirements for a review of judgment

1. Whether the petitioners established a "mistake or error apparent on the face of the record" or any other sufficient reason to justify a review under Order 47 Rule 1 of the Code of Civil Procedure (CPC)

2. Whether the re-assertion of arguments regarding long possession and mutation entries, previously addressed in the Second Appeal, constitutes valid grounds for review

The court primarily applied Section 114 and Order 47 Rule 1 of the CPC, which restrict review jurisdiction to cases involving the discovery of new evidence or an error apparent on the face of the record

It relied on Suraj Bhan v. Financial Commissioner (2007) to affirm that mutation entries are fiscal in nature and do not confer or extinguish title

Furthermore, the court cited Parsion Devi v. Sumitri Devi (1997) and M/s Shanti Conductors (P) Ltd v. Assam State Electricity Board (2020) to establish that a review is not an "appeal in disguise" and cannot be used to re-argue questions already decided

It also referenced M/s Northern India (India) Ltd. v. Lt. Governor of Delhi (1980), holding that a forensic defeat cannot be avenged by an invitation to have a "second look" at the verdict

The court found that the issues raised—specifically the reliance on mutation entries and the length of possession—had already been comprehensively addressed in paragraph 13 of the original judgment

The court noted that the petitioners' possession was determined to be permissive, and thus long-term occupancy did not advance their claim of title

The court reasoned that under Order 47 Rule 1, an error must be "self-evident" and not require a process of reasoning to detect

Since the petitioners were attempting to provoke a re-appreciation of facts and a rehearing on the merits, the court determined this exceeded the narrow scope of review jurisdiction

The court emphasized that the finality of judgments must be respected unless substantial and compelling circumstances exist

The court affirmed that an erroneous decision must be corrected through an appeal, not a review, and that the petitioners failed to identify any manifest error on the face of the record

No order as to costs was made