Review jurisdiction limited to patent error on the record; new lease deed and settled family arrangement could not reopen the judgment.

Review jurisdiction is confined to a manifest and obvious error apparent on the face of the record, and it cannot be used to reopen factual disputes or rely on new material not before the Court. A lease deed produced only with the review petition would require detailed factual examination, so it could not justify review. The Court also noted that the family settlement had been accepted for years, and the underlying judgment had proceeded on that arrangement's validity. For that reason, a separate discussion of the authorities cited on Section 108 of the Companies Act, 1956 was unnecessary. No ground for review was made out, and the review petition was dismissed.

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Issues: Whether the review petition disclosed any patent error apparent on the face of the record so as to warrant exercise of review jurisdiction under Section 114 of the Code of Civil Procedure, and whether the Court had erred in not separately dealing with the authorities relied upon on Section 108 of the Companies Act, 1956.

Analysis: Review lies only where a manifest and obvious error is shown on the face of the judgment. The challenge based on a lease deed produced only with the review petition would require a detailed factual inquiry, which is outside the narrow scope of review. The Court also noted that the petitioner had accepted the family settlement for many years, and the new material was not before the Court when the appeal was decided. As to Section 108 of the Companies Act, 1956, the judgment had proceeded on the validity of the family arrangement and the parties' acceptance of it, making a separate discussion of the cited authorities unnecessary.

Conclusion: No ground for review was made out. The review petition was rightly dismissed.

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