Review jurisdiction is narrow: it cannot reopen settled findings on disciplinary procedure, bias, or evidence absent patent error.

Review jurisdiction under Section 114 and Order 47 CPC is limited to correcting a clear and manifest error apparent on the face of the record, and cannot be used to re-argue issues already decided. The court found that the earlier judgment had already addressed the challenge to admission of additional evidence, alleged bias of the Inquiry Officer, and the complaint of non-supply of findings, with the record showing notice and opportunity to respond and no established bias. The review petition therefore sought a reappraisal of concluded findings rather than correction of a patent error, and was not maintainable on the grounds urged.

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Issues: Whether the petitioner had made out any error apparent on the face of the record warranting review under Section 114 and Order 47 of the Code of Civil Procedure, and whether the earlier findings on alleged violation of inquiry procedure, bias of the Inquiry Officer, and non-supply of findings disclosed any ground for review.

Analysis: Review jurisdiction is confined to correction of an obvious and manifest error and cannot be used to re-argue matters already considered and decided. The earlier judgment had dealt in detail with the challenge to admission of additional evidence during the inquiry, the allegation of bias against the Inquiry Officer, and the contention regarding supply of findings under the disciplinary rules. The record showed that the additional documents were produced with notice and opportunity to respond, that the allegation of bias had not been established, and that the findings had been considered and communicated in the course of disciplinary proceedings. The petition therefore sought a reappraisal of conclusions already reached rather than correction of a patent error.

Conclusion: No error apparent on the face of the record was shown and the review petition was not maintainable on the grounds urged.

Final Conclusion: The judgment affirmed that review cannot be used as an appeal in disguise and that settled findings on procedural fairness and merits will not be reopened absent a manifest legal error.

Ratio Decidendi: Review lies only for a clear and manifest error apparent on the face of the record, and not for re-hearing or substitution of a view on issues already adjudicated.

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