Review jurisdiction is limited to patent errors and cannot be used to reargue the merits.

Review jurisdiction under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure is confined to discovery of new and important evidence, due diligence-based inability to produce material, or an error apparent on the face of the record. An error requiring detailed reasoning or capable of two views does not qualify, and review cannot be used to reopen the merits or obtain a rehearing. Applying that standard, no patent mistake was shown in the order under review, so the review petition was not maintainable.

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Issues: Whether the review petition disclosed any error apparent on the face of the record so as to justify review under the Code of Civil Procedure, 1908.

Analysis: Review under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 is confined to discovery of new and important evidence, inability to produce material despite due diligence, or mistake or error apparent on the face of the record. A review cannot be used to reopen the matter on merits or to seek a rehearing. An error that requires long-drawn reasoning or admits of two possible views is not an error apparent on the face of the record. Applying this standard, the order under review disclosed no such apparent mistake, and the request was in substance an attempt to re-argue the merits.

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

Ratio Decidendi: Review jurisdiction is limited to patent errors or grounds expressly permitted by law, and it cannot be invoked as a substitute for appeal or for reconsideration of the case on merits.

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