Review of an order is not maintainable when the petitioner's interest and opportunity of hearing remain protected.

The petitioner filed a review petition seeking to recall an order dated June 18, 2026, passed in W.P. No. 18447/2017.

The petitioner argued that the original order was passed without notifying him and that the writ petitioner had suppressed material documents regarding the authenticity of his D.Ed. qualification, which he claimed was genuine and verified by the Bharatiya Shiksha Parishad, Uttar Pradesh.

The court noted that its previous order had already directed the Collector to provide the petitioner a hearing.

1. Whether there exists an error apparent on the face of the record or sufficient grounds under review jurisdiction to recall the previous order.

The court applied the substantive provisions of Section 114 and the procedural grounds set out in Order XLVII Rule 1 of the Code of Civil Procedure (CPC), which allow review only for discovery of new evidence, errors apparent on the record, or analogous sufficient reasons.

It relied on Kamlesh Verma v. Mayawati to distinguish between maintainable grounds for review and "appeals in disguise".

The court cited State of West Bengal v. Kamal Sengupta regarding the definition of a patent error.

The court cited Col. Avatar Singh Sekhon v. Union of India regarding the finality of judgments.

The court relied on Parsion Devi v. Sumitri Devi to establish that errors requiring a process of reasoning to detect do not justify review.

The court reasoned that the scope of review is strictly limited and cannot be used to re-argue the merits of a case or correct an erroneous view of law.

It observed that the petitioner’s interests had already been protected in the original writ proceedings because the court had directed the Collector to afford him an opportunity of hearing.

Consequently, the petitioner remained at liberty to produce his qualification documents before the Collector.

The court found that the petitioner failed to demonstrate any "patent error" or "glaring omission" that would undermine the soundness of the previous order.

The court answered the issue in the negative, finding the petition sought a rehearing rather than the correction of a manifest error.

Resultantly, the review petition was dismissed.