Scope of review is limited and cannot be used to re-agitate merits or serve as an appeal in disguise.

The petitioner was appointed as an Assistant Teacher (Shiksha Karmi Class-II) in 1998.

Following confirmation, she remained absent for a prolonged period without authorization, leading to the termination of her services by the CEO, Janpad Panchayat, Sagar on 25.11.2006.

After a substantial delay, she filed a writ petition in 2019 (W.P. No. 1846/2019) initially seeking reinstatement, later amending it to challenge the termination.

The Writ Court dismissed the petition on 24.03.2026 due to laches (delay).

Her subsequent appeal (W.A. No. 1349/2026) was dismissed on 14.05.2026.

The petitioner then filed this review petition under Order 47 Rule 1 of the CPC.

1. Whether a case for review under Order 47 Rule 1 of the CPC is made out based on grounds not raised in the original writ petition or writ appeal.

2. Whether an error apparent on the face of the record exists justifying the modification of the order dated 14.05.2026.

Order 47 Rule 1 of the Code of Civil Procedure, 1908, which governs the limited jurisdiction of review based on a mistake or error apparent on the face of the record.

The scope of review is restricted and cannot be used to re-agitate questions already decided, nor can it serve as an "appeal in disguise" as established in Shanti Conductors (P) Ltd. v. Assam SEB (2020) and Parsion Devi v. Sumitri Devi (1997).

Rule 14 of the M.P. Civil Services (Classification, Control and Appeal) Rules, 1966 regarding disciplinary procedures.

The Court reasoned that the petitioner’s primary ground for review—the alleged non-compliance with Rule 14 of the 1966 Rules—was a fresh argument that had never been raised in the Writ Petition or the Writ Appeal.

The Court observed that the petitioner failed to challenge the termination through available statutory appeals or timely judicial intervention.

Citing Parsion Devi, the bench emphasized that an error must be "self-evident" to justify review; if an error requires a process of reasoning to detect, it does not qualify as an "error apparent on the face of the record".

Since the petitioner was attempting to re-argue the case on merits and introduce new grounds post-dismissal, the Court found the petition exceeded the narrow boundaries of Order 47 Rule 1.

Review Petition No. 1218 of 2026 was dismissed.