Consent order distinction bars review only where the court expressly acts on consent terms, not signed minutes alone.

An order drawn up on signed minutes tendered by counsel to record a concluded position is not, by itself, a consent order barring review. A true consent order arises only where the court expressly passes its order on consent terms, and counsel's signatures on minutes serve identification and binding effect rather than an express consensual adjudication. The Supreme Court held that treating the earlier order as a consent order was incorrect, so the High Court's refusal to entertain the review petition could not stand. The order rejecting review was set aside and the review petition was restored for fresh hearing on merits.

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Issues: Whether an order passed in terms of signed minutes of order is a consent order barring review, and whether the High Court's refusal to entertain the review petition was sustainable.

Analysis: An order passed in terms of minutes tendered by counsel to record a concluded position reached for the court's order is not the same as an order passed by consent of the parties. The signatures of counsel on such minutes serve identification and binding effect, not an express consensual adjudication. A true consent order arises only where the court's order is expressly passed on consent terms. Since the impugned order treated the earlier order as a consent order, the basis for holding the review petition not maintainable was incorrect.

Conclusion: The order rejecting the review petition was set aside and the review petition was restored to the High Court to be heard afresh on merits.

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