Review jurisdiction limited to new material or apparent error; successive review petitions cannot reopen the same order.

Review jurisdiction under Section 114 and Order XLVII Rule 1 CPC is confined to discovery of new and important matter despite due diligence, error apparent on the face of the record, or comparable sufficient reason; it cannot be used to reargue the case, reappreciate evidence, or operate as an appeal in disguise. The Court noted that the certified revenue records were not shown to have been beyond the respondents' knowledge or unavailable earlier despite due diligence, and the material had in substance been available before. Successive review petitions on the same order were therefore impermissible, and the second set of review petitions was not maintainable.

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Issues: Whether the second set of review petitions was maintainable under Order XLVII Rule 1 of the Code of Civil Procedure, 1908 on the ground of discovery of new material or error apparent on the face of the record.

Analysis: Review jurisdiction is confined to the limited grounds in Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908, namely discovery of new and important matter or evidence despite due diligence, error apparent on the face of the record, or analogous sufficient reason. A review cannot be used to reargue the case, reappreciate evidence, or convert the proceeding into an appeal in disguise. The respondents had not pleaded or shown that the certified copies of the revenue records were beyond their knowledge or unavailable despite due diligence before the earlier decision. The material relied upon in the second round had been available earlier in substance, and successive review petitions on the same order were impermissible. The belated attempt to produce the documents was only an effort to fill gaps in the earlier case and did not disclose any reviewable error.

Conclusion: The second set of review petitions was not maintainable and ought to have been rejected.

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