Review requires manifest error, while corporate guarantee may replace bank guarantee where revenue is protected and appeal rights remain intact.

Review is an exceptional remedy and lies only for a manifest error, patent mistake, or other clear ground apparent on the record; mere disagreement with the earlier order is insufficient, so the review petition failed. A direction permitting corporate guarantee instead of bank guarantee was upheld because it addressed financial hardship, safeguarded revenue, and avoided defeating the statutory right of appeal; the challenge to that substitute security was therefore rejected. The modified order remained undisturbed and no costs were imposed.

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Issues: (i) Whether the review petition disclosed any manifest error, patent mistake, or other ground warranting review of the earlier order. (ii) Whether directing furnishing of a corporate guarantee in place of a bank guarantee was legally unsustainable.

Issue (i): Whether the review petition disclosed any manifest error, patent mistake, or other ground warranting review of the earlier order.

Analysis: Review is an exceptional remedy and is permissible only where there is a clear material error apparent on the face of the record or a grave mistake resulting in miscarriage of justice. Mere disagreement with the earlier order, or a reiteration of the same grievance, does not justify review.

Conclusion: No ground for review was made out.

Issue (ii): Whether directing furnishing of a corporate guarantee in place of a bank guarantee was legally unsustainable.

Analysis: The direction was made in the context of the appellant's financial hardship and the practical difficulty of obtaining bank guarantees from banks insisting on full cash margin. The substitute security was treated as sufficient to safeguard the revenue, and insisting on a bank guarantee in those circumstances would have frustrated the statutory right of appeal. The challenge to the corporate guarantee was therefore misconceived.

Conclusion: The direction to furnish a corporate guarantee was upheld.

Final Conclusion: The review petition failed and the modified order directing corporate security in lieu of bank guarantee remained undisturbed, with no costs imposed.

Ratio Decidendi: Review lies only for an apparent and material error or grave injustice, and a court or tribunal may accept an alternate form of security where it preserves the revenue without defeating the right of appeal.

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