Review jurisdiction barred where later CERSAI documents did not show error apparent or justify reopening priority findings.

Review jurisdiction cannot be used to reargue a matter already decided or to obtain a second hearing on the same controversy. The Bombay HC held that the later-produced CERSAI registration documents did not disclose any error apparent on the face of the record or justify reconsideration, because the earlier decision had independently turned on the effect of the existing revenue attachment and proclamation, and on the priority position where such lawful attachment preceded enforcement under Chapter IV-A of the SARFAESI Act and Section 31B of the RDDB Act. No ground for review was made out, and the petition was not maintainable.

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Issues: Whether the review petition disclosed any error apparent on the face of the record or justified reconsideration on the basis of subsequently produced CERSAI registration documents relating to the secured asset.

Analysis: The challenge rested on the assertion that the security interest had been registered with CERSAI and that this new material would alter the earlier conclusion on priority. The Court held that review jurisdiction cannot be invoked for re-agitating matters already decided or for seeking a second round of arguments on the same controversy. The alleged new material did not satisfy the test for review, because the earlier judgment had independently rested on the effect of the pre-existing attachment and proclamation under the revenue laws, and on the legal position governing priority where such lawful attachment preceded enforcement of Chapter IV-A of the SARFAESI Act and Section 31B of the RDDB Act. The Court found no mistake or error apparent requiring reopening of the judgment.

Conclusion: The review petition was not maintainable on the ground of newly produced CERSAI registration documents, and no ground for review was made out.

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