Limited scope of review prevents re-arguing merits; only patent error or new matter can justify reconsideration.

Review jurisdiction under Article 137, Section 114, Order XLVII Rule 1 and the Supreme Court Rules is confined to a patent error, discovery of new matter, or analogous sufficient cause. A review court cannot sit in appeal over its own judgment, reargue issues already considered, or entertain a claim that depends on extended reasoning to show error. The grounds raised were treated as having been examined in the earlier judgment, and the petitions were found to be an attempt to obtain a different view on the merits. No case for review was made out and the petitions were not maintainable on the asserted grounds.

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Issues: Whether the review petitions disclosed any error apparent on the face of the record or any other ground warranting review of the prior judgment.

Analysis: The scope of review under Article 137 of the Constitution of India, Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908, as well as the Supreme Court Rules, 2013, is confined to a patent error, discovery of new matter, or analogous sufficient cause. A review court cannot sit in appeal over its own judgment, reargue matters already considered, or entertain a contention that requires a long-drawn process of reasoning to establish error. The grounds urged were held to have already been examined in the earlier judgment and the review was found to be an attempt to secure a different view on the merits.

Conclusion: No case for review was made out; the petitions were not maintainable on the asserted grounds and were liable to be dismissed.

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