Review lies only for a demonstrated error apparent or new evidence, not reargued factual distinctions.

The Review Applicants—primarily Bharat Sanchar Nigam Limited and its officers—sought review of the common order dated 25 August 2025 passed in the connected Original Applications concerning the service claims of the respondents, who included BSNL employees and retirees.

The Review Applications challenged the common adjudication on the ground that the individual cases involved materially different factual and legal circumstances which, according to the applicants, had not been separately considered.

The applicants contended that two issues—the date of the Presidential Order and the absorption order—did not require reconsideration, but that five remaining questions required separate examination.

They further submitted that O.A. Nos. 180/00469/2019 and 180/00415/2019 did not raise any substantive issue requiring review and had been included only because they formed part of the common order.

The Tribunal had earlier directed on 23 September 2024 that the matters be heard in three groups: O.A. Nos. 415/2019 and 469/2019; O.A. Nos. 124/2019, 105/2019 and 900/2019; and O.A. Nos. 397/2019 and 870/2018.

That grouping order was not challenged by the parties.

Whether the common order dated 25 August 2025 was liable to be reviewed because the Tribunal allegedly failed to account for differences in the factual and legal circumstances of the individual Original Applications.

Whether the Review Applicants had established a discovery of new evidence or an error apparent on the face of the record sufficient to justify review.

Whether the mere fact that a common order was passed in grouped matters constituted a ground for review.

The Tribunal applied the limited scope of review jurisdiction, under which a judgment may be reviewed only on recognised grounds such as discovery of new and important evidence or an error apparent on the face of the record; review is not an occasion for rehearing or reconsideration of matters already adjudicated.

It further applied the principle that connected matters may be decided through a common order where the common order identifies and separately addresses the relevant factual categories and issues.

The Tribunal found that the grouping of the Original Applications had been expressly ordered on 23 September 2024 and had never been objected to by the Review Applicants.

It held that the impugned common order did not mechanically treat all cases as identical: the factual circumstances of each set of cases had been dealt with separately, while common legal submissions had been considered together.

The final portion of the original order had also categorised the employees and declared their respective legal status accordingly.

Although the applicants alleged factual errors and failure to consider material differences, they did not identify any specific factual error or demonstrate that any material placed before the Tribunal had been ignored.

Consequently, the objections amounted to an attempt to reopen the merits rather than establish an error apparent or newly discovered evidence warranting review.

It held that the existence of factual variations between connected cases, and the passing of a common order, did not by themselves disclose an error apparent on the face of the record.

As no recognised ground for review was established, all seven Review Applications were dismissed.