Civil court review power is limited to statutory bounds and cannot reopen concluded substantive findings on tenancy suo motu.

A civil court has no inherent power to review its own concluded findings; review exists only if conferred by statute and only within the limits of that statute. The narrow exception permitting correction of a procedural or inadvertent error on the court's own motion does not extend to reopening a substantive finding already decided on merits. On the facts stated, the conclusion that the question of tenancy did not arise was a substantive determination, not a procedural step, so it could not be revisited suo motu merely because it was later viewed as erroneous. The resulting review order was without jurisdiction.

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Issues: Whether a civil court has power to suo motu review a concluded finding on an issue in a suit, and whether such power can be exercised only where the earlier order suffers from a procedural or inadvertent error.

Analysis: The power of review is not an inherent power of a civil court and exists only when conferred by statute and within the limits prescribed by that statute. A civil court may, in a narrow class of cases, correct a procedural or inadvertent error on its own motion, but that exception does not extend to reopening a substantive finding on an issue already concluded on merits. A finding that the question of tenancy did not arise was a substantive determination, not a procedural step. The earlier conclusion could not therefore be revisited suo motu merely because the judge later considered it to be erroneous.

Conclusion: The civil court had no authority to suo motu review its concluded finding on the issue of tenancy, and the order making such review was without jurisdiction.

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