Review jurisdiction: non-consideration of material statutory provisions can amount to sufficient reason for recall and reconsideration.

Review jurisdiction under Section 114 and Order XLVII Rule 1 CPC is confined to discovery of new matter, apparent error, or other sufficient reason, but "sufficient reason" may extend to a misconception of fact or law where analogous statutory grounds are met. Non-consideration of material statutory provisions and relevant record circumstances, already available but not addressed when the writ petition was heard, can justify review if that omission could materially affect the result. On that basis, the review was maintainable, the earlier order dismissing the writ petition was recalled, and the writ petition was restored for reconsideration.

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Issues: Whether the order dismissing the writ petition required review on the ground that material statutory provisions and relevant facts were not brought to the Court's attention, thereby constituting sufficient reason under the review jurisdiction.

Analysis: Review under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 is confined to the recognized grounds of discovery of new and important matter, error apparent on the face of the record, or other sufficient reason. The expression "sufficient reason" is wide enough to include a misconception of fact or law, but the applicant must still show grounds analogous to the statutory grounds and satisfy the requirements of due diligence and inability to place the matter earlier. On the record, the Court found that the petitioner's case had not been argued with reference to the relevant provisions governing quantification and eligibility under the Sabka Vishwas scheme, and that these provisions and surrounding circumstances were already available on record. The omission to draw attention to those provisions could materially affect the earlier outcome.

Conclusion: The review was maintainable and the earlier order required recall.

Final Conclusion: The order dismissing the writ petition was set aside in review, and the writ petition was restored for reconsideration.

Ratio Decidendi: Non-consideration of material statutory provisions and material record circumstances, where they could materially affect the result, can constitute sufficient reason for review within Order XLVII Rule 1 of the Code of Civil Procedure, 1908.

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