High Court review power extends to correcting an apparent error on the record despite a limited statutory review provision.

A High Court, as a superior court of record under Article 215, retains inherent power to correct an error apparent on the face of the record, even where the statutory review provision is framed in limited terms. The earlier judgment was vulnerable because it granted exemption under Section 3(2) although the claim had been pleaded and evidenced only under Section 3(3), with no basis for relief under Section 3(2). That mismatch constituted an apparent error, so the review was maintainable and the High Court could revisit its judgment.

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Issues: Whether the High Court could review its earlier judgment under the Kerala Private Forests (Vesting and Assignment) Act, 1971, and whether the earlier judgment suffered from an error apparent on the face of the record.

Analysis: The review provision in Section 8C(2) was considered in the context of the High Court's status as a Court of Record. The earlier judgment had allowed exemption under Section 3(2) even though the claim had been founded on Section 3(3), and there was no basis in the pleadings or evidence for a claim under Section 3(2). That mistake was treated as an error apparent on the face of the record. The Court further held that the High Court, as a superior court of record under Article 215 of the Constitution of India, has inherent and plenary power to correct its own record and is not wholly confined by the statutory review provision where an apparent error is shown.

Conclusion: The High Court had power to review its judgment and the review could be sustained on the ground of apparent error.

Ratio Decidendi: A High Court, as a Court of Record under Article 215 of the Constitution of India, inherent power to correct an error apparent on the face of its record, and such power is not excluded merely because the statutory review provision is framed in limited terms.

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