Review jurisdiction limited to patent error on the record; merits cannot be reopened without an apparent mistake.

Review under the repealed Foreign Exchange Regulation Act, 1973 remained governed by the saving provisions in the Foreign Exchange Management Act, 1999 and the General Clauses Act, 1897, preserving the earlier rights, liabilities and remedies. The Tribunal held that review jurisdiction is confined to correction of a patent error apparent on the face of the record or a clerical mistake, and cannot be used to reargue the merits or function as an appeal in disguise. As the applicant sought a fresh consideration of factual and legal issues without showing any apparent error in the earlier order, no ground for review was established and the petition was rejected.

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Issues: Whether the review petition was maintainable in respect of the Tribunal's earlier order and whether any ground was shown for review on the basis of an error apparent on the face of the record.

Analysis: The Tribunal held that the adjudication arose under the repealed Foreign Exchange Regulation Act, 1973, and that the saving provisions in the Foreign Exchange Management Act, 1999 and the General Clauses Act, 1897 preserved the rights, liabilities, and remedies under the repealed regime. It further held that the power of review could not be used to re-agitate the merits of the case, because review is confined to correction of patent error or clerical mistake and cannot operate as an appeal in disguise. Since the applicant sought a rehearing on factual and legal merits rather than demonstrating any apparent error in the earlier order, no ground for review was made out.

Conclusion: The review petition was not maintainable and was rejected.

Final Conclusion: The earlier order remained undisturbed, and no substantive reopening of the merits was permitted.

Ratio Decidendi: A review lies only for a patent error apparent on the face of the record or similar limited procedural defect, and it cannot be used to reopen a concluded decision on merits where no such apparent error is shown.

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