Review petition is not maintainable for rehearing a case or correcting alleged errors through process of reasoning.

The petitioner filed a review petition under Order 47 Rule 1 of the CPC against an order dated April 27, 2026, passed in W.P. No. 3059/2017

In the original writ petition, the High Court had directed the Collector of District Bhind to conduct an inquiry against the petitioner (respondent No. 6 in the writ) based on a complaint and a report from the Rural Engineering Services

The petitioner sought a recall of that order, arguing that there were no specific allegations against him

1. Whether the petitioner made out a case for the exercise of review jurisdiction based on an error apparent on the face of the record or the discovery of new evidence

2. Whether the court’s previous direction to conduct an inquiry, while providing the petitioner with an opportunity to be heard, constituted a miscarriage of justice or a patent error

The court primarily applied Order 47 Rule 1 and Section 114 of the Code of Civil Procedure (CPC), which limit review to cases involving the discovery of new evidence, mistakes or errors apparent on the face of the record, or other analogous "sufficient reasons"

The court relied on Kamlesh Verma v. Mayawati, emphasizing that a review is not a "rehearing" or an "appeal in disguise" and cannot be granted for minor mistakes or the possibility of a different view

It cited State of West Bengal v. Kamal Sengupta to clarify that an "error apparent" must be prima facie visible without detailed examination

Col. Avatar Singh Sekhon v. Union of India, which establishes that a review is a serious step only taken to correct glaring omissions or patent mistakes

The court reasoned that the petitioner failed to demonstrate any manifest error or discovery of new material that would undermine the original order's soundness

The court noted that the previous order already protected the petitioner's rights by mandating a personal opportunity of being heard during the Collector's inquiry

The court observed that the petitioner’s arguments—specifically that there were no allegations against him—could be raised directly before the Collector during the inquiry process rather than through a review

Following the principles in Parsion Devi v. Sumitri Devi, the court determined that since the alleged error was not self-evident and would require a process of reasoning to detect, it did not satisfy the strict criteria for review jurisdiction

Consequently, the review petition was dismissed

The court maintained its previous direction for the Collector to conclude the inquiry within four months, ensuring all parties, including the petitioner, are heard in accordance with the law