Writ jurisdiction cannot be invoked to bypass statutory inquiry into disputed questions of fact regarding revenue entries.

The appellant’s ancestral lands (34.33 acres) were requisitioned during WWII for transit/refugee camps.

Despite subsequent release orders and directions from the Collector, Raipur, for mutation in the name of the appellant’s father, the revenue records were incorrectly updated in 1987 to show the State Government as the owner.

After several rounds of litigation (WP No. 2928/2004 and WPC No. 380/2012), a Nayab Tahsildar’s report in 2018 confirmed the appellant’s possession and lack of government title documents, yet the application for correction was rejected.

The appellant challenged this in WPC No. 4724/2021, where the Single Judge directed a "fresh inquiry".

The appellant filed a Review Petition (No. 171/2021) arguing that multiple inquiries had already occurred, but it was dismissed on 23.01.2026.

1. Whether the Single Judge erred in directing a fresh inquiry despite existing revenue reports recommending correction of records in favor of the appellant.

2. Whether there was an error apparent on the face of the record justifying the review of the order dated 23.11.2021.

The court applied the principle that in matters concerning correction of revenue entries involving disputed questions of fact and historical transactions, the competent revenue authority—not the High Court under Article 226—is the appropriate forum for factual adjudication.

Regarding the review jurisdiction, the court applied the settled principle that a review is limited to "errors apparent on the face of the record" or the discovery of new evidence, and cannot be used to re-argue the original case.

The Division Bench observed that the Single Judge’s direction for a fresh inquiry did not determine final rights but facilitated a reasoned adjudication by a statutory authority based on records.

The court reasoned that since the reports relied upon by the appellant were "recommendatory" and part of an administrative process rather than final adjudications, the competent authority must independently scrutinize all materials, including past correspondence and stakeholder claims.

The court further found that the appellant’s review petition merely repeated original arguments, which does not meet the threshold of an "error apparent on the face of record".

The Court dismissed the appeal and affirmed the orders passed in WPC No. 4724/2021 and Review Petition No. 171/2021.