Review jurisdiction remains narrow: delay was condoned, but no error apparent justified reopening the earlier judgment.

Review jurisdiction is confined to the narrow grounds recognised under principles analogous to Order XLVII CPC and cannot be used for re-argument or mere reappreciation of an earlier decision. The High Court accepted the explanation for delay and condoned the belated filing of the review application, but found no error apparent on the face of the record or other basis justifying review. The objection related only to a passage that recorded a contention and did not affect the core reasoning, so the review was not maintainable on merits and the earlier judgment remained undisturbed.

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Issues: (i) Whether the delay in filing the review application deserved condonation. (ii) Whether the review application disclosed grounds warranting exercise of review jurisdiction under the principles analogous to Order XLVII of the Code of Civil Procedure, 1908.

Issue (i): Whether the delay in filing the review application deserved condonation.

Analysis: The explanation furnished for the delay was accepted as sufficient to account for the belated filing of the review application.

Conclusion: The delay was condoned and the application for condonation was allowed.

Issue (ii): Whether the review application disclosed grounds warranting exercise of review jurisdiction under the principles analogous to Order XLVII of the Code of Civil Procedure, 1908.

Analysis: Review jurisdiction is confined to narrow grounds and cannot be invoked merely because a party seeks reappreciation of the earlier decision. The Court found no ingredient justifying review, and held that the alleged error apparent on the face of the record was not made out, as the objection was directed against a portion of the judgment that had only recorded a contention and did not affect the ultimate reasoning.

Conclusion: The review application was not maintainable on merits and was dismissed.

Final Conclusion: The review was entertained after condoning delay, but no ground for reopening the earlier judgment was established, so the earlier decision remained undisturbed.

Ratio Decidendi: Review jurisdiction is exceptional and can be exercised only on legally recognised grounds under Order XLVII of the Code of Civil Procedure, 1908, and not for re-arguing the case or correcting matters that do not constitute an error apparent on the face of the record.

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