Review jurisdiction is limited to patent errors on the record; vague delay explanations do not justify condonation.

Review jurisdiction under Order 47 Rule 1 CPC is confined to correcting an error apparent on the face of the record; it cannot be used to reargue the case, seek rehearing on merits, or substitute one possible view for another. On that standard, the review application disclosed no such error and was not maintainable. The request to condone delay also failed because the explanation was vague, unsupported by dates, and did not show sufficient cause for exercising discretion in favour of the applicant. The proceedings therefore failed on both merits and limitation, and the incidental direction concerning the alternative plot claim did not affect that result.

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Issues: (i) whether the review application disclosed any error apparent on the face of the record warranting exercise of review jurisdiction; (ii) whether the delay in filing the review application deserved condonation.

Issue (i): whether the review application disclosed any error apparent on the face of the record warranting exercise of review jurisdiction.

Analysis: Review jurisdiction under Order 47 Rule 1 of the Code of Civil Procedure is confined to correction of an obvious mistake or patent error apparent from the record. It cannot be invoked to re-argue the matter, substitute one possible view for another, or secure rehearing on merits. A review petition cannot be treated as an appeal in disguise, and an error requiring a long process of reasoning is outside the scope of review.

Conclusion: The review application disclosed no error apparent on the face of the record and was not maintainable in review.

Issue (ii): whether the delay in filing the review application deserved condonation.

Analysis: The application for condonation did not disclose sufficient cause. The delay explanation was vague, unsupported by dates, and failed to furnish any cogent basis for exercising discretion in favour of the applicant. The application was also beyond the limitation period prescribed for review.

Conclusion: The delay was not condoned.

Final Conclusion: The review proceedings failed both on merits and on limitation, and the incidental direction regarding consideration of the alternative plot claim did not alter the dismissal of the applications.

Ratio Decidendi: Review lies only to correct an error apparent on the face of the record and cannot be used to reopen the case or substitute a different view on the merits.

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