Criminal review jurisdiction is narrow: no rehearing, no reappreciation of evidence, and no relief without manifest error.

Supreme Court review in criminal matters is confined to an error apparent on the face of the record or a comparable manifest error causing miscarriage of justice; it is not a rehearing or an appeal in disguise. Applying that standard, the Court found no patent error in the affirmed conviction and death sentence, rejected attempts to reappreciate evidence, and held that objections to the tape-recorded conversation and to sentencing did not disclose any ground for review. The earlier judgment therefore remained undisturbed.

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Issues: Whether the review jurisdiction of the Supreme Court could be invoked in a criminal matter only on the ground of error apparent on the face of the record or other material error causing miscarriage of justice; whether the applicants had shown any such error warranting reopening of the judgment affirming conviction and death sentence; and whether the objections regarding admissibility of the tape-recorded conversation or the sentence imposed disclosed any ground for review.

Issue (i): Whether the review jurisdiction of the Supreme Court could be invoked in a criminal matter only on the ground of error apparent on the face of the record or other material error causing miscarriage of justice.

Analysis: The power of review under Article 137 is wide, but in criminal proceedings it is regulated by the Supreme Court Rules and ordinarily is confined to error apparent on the face of the record. Review is not a rehearing of the appeal, not an appeal in disguise, and cannot be used to re-argue concluded issues or invite a different view on the same material. The governing test is whether a glaring omission, patent mistake, or material error manifest on the record has resulted in miscarriage of justice.

Conclusion: The review jurisdiction is limited and can be exercised only on recognized review grounds, not to reopen the appeal on merits.

Issue (ii): Whether the applicants had shown any such error warranting reopening of the judgment affirming conviction and death sentence.

Analysis: The objections raised sought reappreciation of evidence, including the recording of conviction under Sections 302 and 364A of the Indian Penal Code and the affirmation of the death sentence. The Court found that the conviction had been based on ocular, medical, and other corroborative evidence and that the sentence question had already been considered in the light of the governing principles for capital punishment. No patent error, inadvertent mistake, or manifest injustice was demonstrated.

Conclusion: No ground for review was made out on the merits of conviction or sentence.

Issue (iii): Whether the objections regarding admissibility of the tape-recorded conversation or the sentence imposed disclosed any ground for review.

Analysis: The tape-recorded conversation relied upon was treated as primary evidence, so the absence of a certificate under Section 65B did not render it inadmissible. The challenge to the sentence under the provisions relating to murder and kidnapping for ransom was also rejected because the sentence had already been upheld after considering the relevant aggravating and mitigating circumstances, and the review petition only attempted to revisit matters already decided.

Conclusion: The evidentiary and sentencing objections did not disclose any error apparent on the face of the record.

Final Conclusion: The judgment held that the review petitions did not satisfy the strict requirements for review and that the earlier conviction and sentence would remain undisturbed.

Ratio Decidendi: Review of a criminal judgment is maintainable only for an error apparent on the face of the record or a comparable manifest error causing miscarriage of justice, and it cannot be used to reappreciate evidence or seek a rehearing on issues already decided.

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