Review jurisdiction is limited to patent error and cannot be used to reopen merits or reappreciate evidence.

Review jurisdiction under Section 114 and Order 47 Rule 1 CPC is confined to a patent, self-evident error on the face of the record or other limited recognised grounds. A review cannot be used as a substitute for appeal, nor to obtain a rehearing by reappreciating evidence or revisiting the merits merely because another view is possible. The Madhya Pradesh High Court noted that no apparent error was shown and that the petition in substance sought reconsideration of the earlier order's merits. No ground for review was made out, and the petition was liable to be dismissed.

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Issues: Whether the review petition disclosed any error apparent on the face of the record warranting exercise of review jurisdiction under Section 114 and Order 47 Rule 1 of the Code of Civil Procedure, 1908, and whether the petition sought impermissible reappreciation of the merits of the earlier decision.

Analysis: Review jurisdiction is confined to the narrow grounds recognised by Section 114 and Order 47 Rule 1 of the Code of Civil Procedure, 1908. An error must be self-evident and patent, not one requiring detailed examination or long-drawn reasoning. A review cannot be used as a substitute for an appeal, nor can it be invoked merely because another view on the merits is possible. The Court found that no such apparent error had been shown and that the review petition, in substance, attempted to challenge the merits of the earlier order. Reappreciation of evidence and rehearing of the matter were therefore impermissible.

Conclusion: No ground for review was made out, and the petition was liable to be dismissed.

Ratio Decidendi: Review lies only for a patent and self-evident error or other limited grounds within Order 47 Rule 1, and it cannot be used to reopen the merits or reappreciate evidence.

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