Review jurisdiction under CPC cannot reopen omitted arguments or serve as an appeal in disguise.

Review under Section 114 and Order 47 Rule 1 CPC is confined to discovery of new and important matter despite due diligence, an error apparent on the face of the record, or a sufficient analogous reason. Grounds that were available in the original appeal but were not urged, including a change of counsel or a wish to advance fresh arguments, do not satisfy those limits. Review cannot be used as an appeal in disguise or as a means to obtain a rehearing on merits, and Section 151 cannot override the specific statutory restrictions. The review application was therefore not maintainable and was rightly rejected.

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Issues: Whether the review application was maintainable on the basis of grounds not urged in the original appeal, including a change of counsel and alleged errors said to arise from omitted arguments.

Analysis: Review under Section 114 and Order 47 Rule 1 of the Code of Civil Procedure, 1908 is confined to discovery of new and important matter despite due diligence, error apparent on the face of the record, or a sufficient reason analogous to those grounds. Grounds that were available earlier but were not taken in the appeal, or the attempt to re-open the matter because a different counsel now wishes to advance new arguments, do not satisfy the statutory limits of review. The Court also held that review cannot be used as an appeal in disguise or as a device to secure a fresh hearing on merits, and that inherent powers under Section 151 cannot override the specific statutory remedy and its restrictions.

Conclusion: The review application was not maintainable and was rightly rejected.

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