Review jurisdiction is limited to errors apparent on the record and excludes re-argument of merits.

The review applicant, a 67-year-old retired employee, filed a Review Application (RA) under Section 22(3)(f) of the Administrative Tribunals Act, 1985

He sought a review of the Tribunal's order dated 22.12.2025, which had quashed an order dated 01.04.2022 and directed the respondents to pay simple interest at GPF rates on delayed arrears of salary and retiral benefits from 01.10.2019 until the date of payment

The applicant contended that the Tribunal failed to consider the retrospective application of a 2019 MACP policy (w.e.f. 01.09.2008), misappreciated the precedent in Smt. S. Geetanjali vs. UOI & Ors., and erred in not granting interest from the actual date of retirement

1. Whether there exists an error of fact or law apparent on the face of the record in the order dated 22.12.2025 that justifies the exercise of review jurisdiction

2. Whether a party can seek a review to re-argue the merits of the case or challenge an allegedly erroneous decision under the guise of Section 22(3)(f) of the Administrative Tribunals Act

The Tribunal applied Section 22(3)(f) of the Administrative Tribunals Act, 1985, which grants the Tribunal power to review its decisions akin to the power of a Civil Court under Section 114 read with Order 47 Rule 1 of the CPC

It relied on the principles established in State of West Bengal & Ors. v. Kamal Sengupta & Anr. (2008), which stipulate that a review is maintainable only for "errors apparent on the face of the record" and not for correcting erroneous decisions

Furthermore, the court cited Union of India v. Tarit Ranjan Das (2004) and Ajit Kumar Rath v. State of Orissa (1999) to affirm that review is limited to cases involving discovery of new evidence or self-evident errors, rather than a long process of reasoning

The Tribunal found that the review applicant was attempting to re-argue the matter by raising facts and contentions that had already been duly considered during the original hearing

It reasoned that the scope of review is strictly limited; it cannot be used as an appeal in disguise or to correct a decision on the ground that it is erroneous

The Tribunal noted that an error is only "apparent" if it is self-evident and does not require a complex process of reasoning to discover

Since the applicant’s grounds—concerning the retrospective MACP policy and the interpretation of precedents—involved re-examining the merits of the initial adjudication, the Tribunal concluded that no "sine qua non" error apparent on the record existed

It reiterated that the power of review must be confined to the material available at the time of the initial decision

Consequently, the Tribunal dismissed the Review Application in circulation