Review jurisdiction is limited to new evidence or an apparent error; rehearing on compensation merits was impermissible.

Review under Article 137 and Order 47 Rule 1 is limited to discovery of new and important matter despite due diligence, or an error apparent on the face of the record. The additional documents did not show that the earlier sale transaction was sham or that the vendor and vendee were under common control, and they did not explain why the evidence was not produced before the Reference Court despite comparable sale instances already on record. The Court treated the petitions as an impermissible attempt to reopen the merits, and no case for review was made out.

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Issues: Whether the review petitions disclosed any error apparent on the face of the record or any newly discovered material, after due diligence, warranting reconsideration of the earlier judgment on compensation.

Analysis: The applicable review jurisdiction under Article 137 of the Constitution of India, read with Order 47 Rule 1 of the Code of Civil Procedure, 1908, is confined to discovery of new and important matter or evidence not earlier available despite due diligence, or to an error apparent on the face of the record. The documents produced with the review petitions did not establish that the sale transaction relied upon earlier was a sham or that the vendor and vendee were under common control so as to vitiate the valuation exercise. The material also failed to explain why no such evidence was led before the Reference Court, especially when the record already contained comparable sale instances. The attempt was, in substance, a request for rehearing on merits, which is impermissible in review.

Conclusion: No case for review was made out, and the challenge to the earlier compensation determination failed.

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