Review jurisdiction barred by unexplained delay and later change in law cannot justify reopening an order under CPC review rules.

An inordinate 690-day delay in filing the review petition was not satisfactorily explained, so the petition was liable to dismissal on limitation alone. On merits, review was unavailable because the impugned order had correctly followed an existing three-Judge Bench precedent, and a possible later reconsideration of that precedent in another case could not invalidate the order under review. Applying the Explanation to Order 47 Rule 1(2) CPC, the SC reiterated that a later reversal or modification of law in a different matter is not a ground for review. The review petition was therefore rejected as both time-barred and meritless.

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Issues: Whether the review petition was barred by limitation on account of unexplained delay, and whether a subsequent or pending decision of a larger Bench could furnish a ground for review on merits.

Analysis: The delay of 690 days was found to be not satisfactorily explained, rendering the review petition liable to dismissal on limitation alone. Independently, the petition also failed on merits because the impugned order had followed an existing three-Judge Bench decision, and the possibility of that precedent being reconsidered in another case did not affect the validity of the order under review. The explanation to Order 47 Rule 1(2) of the Code of Civil Procedure was applied to hold that a later reversal or modification of the law by a superior court in another case cannot constitute a ground for review.

Conclusion: The review petition was not maintainable on limitation and also failed on merits, and it was rejected.

Final Conclusion: Review jurisdiction cannot be invoked on the basis of a later possible change in law, and an inadequately explained delay is sufficient to defeat the petition.

Ratio Decidendi: A subsequent decision reversing or modifying the legal basis of a judgment in another case is not a ground for review, and an unexplained inordinate delay independently justifies dismissal of the review petition.

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