Review jurisdiction is restricted to correcting patent errors and cannot be used for re-hearing or fresh arguments.

The Applicant, a Manager at RITES-SAIL, filed an Original Application (OA No. 927/2019) which was dismissed by the Tribunal on 06.01.2026 after a full hearing and consideration of documents on record

The Applicant subsequently filed the present Review Application (RA No. 13/2026) seeking a review of the dismissal order.

The Tribunal noted that the grounds raised in the RA were identical to those already considered and decided in the original proceedings

It further noted that a related matter, OA No. 203/341/2023, had been disposed of based on the consent of both parties

1. Whether the grounds raised by the Applicant fall within the narrow scope of review jurisdiction as contemplated under Section 114 and Order XLVII Rule 1 of the CPC

2. Whether there exists an "error apparent on the face of the record" in the order dated 06.01.2026 that warrants the exercise of review power

The Tribunal’s power of review under Section 22(3)(f) of the Administrative Tribunals Act, 1985, is analogous to the power of a Civil Court under Section 114 read with Order XLVII Rule 1 of the CPC

Relying on Ajit Kumar Rath v. State of Orissa, the court noted that review is not a tool for a fresh hearing or to correct an "erroneous view," but is strictly for correcting patent errors of law or fact

Under Meera Bhanja v. Nirmala Kumari Choudhury, an error apparent must be self-evident and not require a long-drawn process of reasoning

Furthermore, as held in Union of India v. Tarit Ranjan Das, a review forum cannot act as an appellate authority to facilitate a change of opinion on merits

The comprehensive principles in State of West Bengal v. Kamal Sengupta dictate that review is impermissible for discovering new matters that could have been produced earlier with due diligence or based on subsequent judgments

The Tribunal analyzed the Applicant's submissions and concluded that the application was an attempt to seek a rehearing under the "garb" of a review

The court reasoned that since all grounds raised had been previously adjudicated, the Applicant was essentially asking the Tribunal to act as an appellate court over its own order, which is legally impermissible

The Tribunal applied the "error apparent" test, finding that no patent mistake was visible on the face of the record without elaborate argument

Since the Applicant failed to bring the application within the specific grounds enumerated in Order XLVII Rule 1 of the CPC—such as the discovery of new evidence or a self-evident legal error—the Tribunal found no justification to exercise its limited review jurisdiction

The Tribunal dismissed the Review Application at the circulation stage