Scope of review jurisdiction is limited to patent errors and excludes rehearing on merits or erroneous legal views.

The petitioner filed a review petition seeking to set aside the order dated 24/02/2026 passed in Writ Appeal No. 274/2026, which had dismissed the petitioner’s appeal

The petitioner contended that on the date of the appellate hearing, his arguing counsel was on adjustment and a proxy counsel had only requested an adjournment

On the merits, the petitioner challenged the demand for enhanced premium and land revenue. However, the State argued that the land was diverted for residential/commercial use via an order dated 28/07/2017, and the petitioner had already accepted the demand by paying ₹2,00,000/-

1. Whether a review of the appellate order is maintainable on the grounds of counsel's absence and alleged procedural irregularities in land revenue assessment

2. Whether the error pointed out by the petitioner constitutes a "mistake or error apparent on the face of the record" under the established scope of review jurisdiction

The Court applied the principles of review jurisdiction as articulated in Kamlesh Verma v. Mayawati and Others (2013) 8 SCC 320, which distinguishes between maintainable grounds (discovery of new evidence, error apparent on the face of the record) and non-maintainable grounds (repetition of arguments, merits of an appeal in disguise)

It further relied on State of West Bengal & Ors. v. Kamal Sengupta & Anr. (2008) 8 SCC 612, establishing that a "mistake apparent on the face of record" must be prima facie visible without detailed examination and that an erroneous view of law is not a ground for review

The Court reasoned that the petitioner failed to challenge the original diversion order dated 28/07/2017, which had consequently attained finality

The Court noted that the petitioner had partially complied with the demand by paying ₹2,00,000/-, undermining the argument against the assessment’s validity

Regarding the procedural claim of counsel adjustment, the Court found that the Writ Appellate Court had already considered the necessary factual facets and that the review petition was essentially seeking a rehearing on merits

Applying the Kamlesh Verma standard, the Court determined that the petitioner’s arguments did not reveal a patent error but rather sought to use the review process as an "appeal in disguise," which is legally impermissible

The Court affirmed that the previous order of the Writ Appellate Court was based on a sound consideration of facts and that the diversion order of 2017 remained valid and binding