Review jurisdiction limited to patent error only; a petition cannot reopen a decided pre-deposit issue on merits.

Review jurisdiction under Section 114 read with Order 47 Rule 1 CPC is limited to discovery of new matter, mistake, error apparent on the face of the record, or other sufficient reason of a like nature, and it cannot be used for rehearing or reappreciation of the merits. In the stated matter, the prior refusal of relief rested on non-fulfilment of the mandatory pre-deposit requirement under Section 129(3) of the Customs Act, 1962, and no patent error in that order was shown. The review petition was therefore treated as an attempt to reopen the decided issue and was rejected.

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Issues: Whether the review petition disclosed any error apparent on the face of the record warranting review of the earlier order declining relief on the ground of non-fulfilment of the mandatory pre-deposit under Section 129(3) of the Customs Act, 1962.

Analysis: Review jurisdiction under Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure, 1908 is confined to discovery of new matter, mistake, or error apparent on the face of the record, or other sufficient reason of a like nature. Such jurisdiction does not permit rehearing of the matter, reappreciation of evidence, or correction of an allegedly erroneous decision on merits merely because another view is possible. The earlier order had been passed on the merits of the controversy and the petitioner did not demonstrate any self-evident or patent error in that order.

Conclusion: No error apparent on the face of the record was shown, and the review petition was not maintainable as a disguised attempt to reopen the decided matter. The review was rejected.

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