Review jurisdiction is narrow and a direct Article 32 challenge to a binding Constitution Bench judgment is not maintainable.

Review jurisdiction under Article 137 read with Order XLVII is narrow and is confined to discovery of new material, an error apparent on the face of the record, or similar sufficient reason; it cannot be used to reargue issues already decided. On that basis, the review challenge to the earlier Sabarimala Constitution Bench judgment failed. A direct writ petition under Article 32 attacking that binding judgment was held not maintainable, and the constitutional duty of authorities to act in aid of the Supreme Court was emphasised. The collateral writ proceedings were dismissed, with directions for publicity, compliance, and maintenance of public order.

---

---

Issues: (i) Whether any ground for review was made out against the earlier Constitution Bench judgment on the Sabarimala issue. (ii) Whether the writ petitions directly attacking the earlier judgment under Article 32 were maintainable and what consequential directions were warranted.

Issue (i): Whether any ground for review was made out against the earlier Constitution Bench judgment on the Sabarimala issue.

Analysis: Review jurisdiction under Article 137 read with Order XLVII of the Supreme Court Rules, 2013 is narrow and lies only for discovery of new material, error apparent on the face of the record, or analogous sufficient reason. The challenges raised largely sought a rehearing of issues already decided, including religious denomination, essential religious practice, Article 25, Article 26, constitutional morality, and Article 17. Such reconsideration is impermissible in review. The majority conclusions of the earlier judgment were found to disclose no manifest error warranting interference.

Conclusion: No ground for review was made out, and the review petitions failed.

Issue (ii): Whether the writ petitions directly attacking the earlier judgment under Article 32 were maintainable and what consequential directions were warranted.

Analysis: A direct writ petition under Article 32 challenging a Constitution Bench judgment was held not maintainable. The decision also emphasised the constitutional duty of all civil and judicial authorities to act in aid of the Supreme Court, and underscored that the binding declaration of law must be implemented in accordance with the constitutional scheme. Directions were issued for wide publicity of the judgment and for the State to take steps to secure compliance and maintain public order.

Conclusion: The writ petitions were not maintainable and stood dismissed, with consequential directions for implementation and publicity.

Final Conclusion: The challenge to the earlier Sabarimala judgment did not survive review, and the collateral writ proceedings were rejected, while the authorities were directed to act in aid of and give effect to the binding decision of the Court.

Ratio Decidendi: Review cannot be used as an appeal in disguise or to reargue matters already decided, and a direct constitutional challenge to a binding Constitution Bench judgment is not maintainable under Article 32.

---