Review jurisdiction is limited to patent error or new material; rearguing the merits is not a valid ground for recall.

Review jurisdiction under Section 114 and Order XLVII Rule 1 CPC is limited to discovery of new and important matter, mistake or error apparent on the face of the record, or analogous sufficient reason. A review cannot be used to reargue the case, reappreciate evidence, or act as an appeal in disguise. Because no patent error or new material was shown, and the challenge only sought to reopen the earlier conclusion, the review petition was held not maintainable and was rejected, leaving the earlier order undisturbed.

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Issues: (i) Whether the review petition disclosed any ground under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 to recall the earlier order dismissing the appeal for want of a substantial question of law.

Analysis: Review jurisdiction is confined to discovery of new and important matter or evidence, mistake or error apparent on the face of the record, or analogous sufficient reason. A review cannot be used to reargue the matter, reappreciate evidence, or convert the proceeding into an appeal in disguise. An error must be self-evident and not one that requires elaborate reasoning or fresh examination of the merits. On the record, no such patent error or new material was shown, and the challenge was only an attempt to reopen the earlier conclusion.

Conclusion: The review petition was not maintainable on the grounds invoked and was rejected.

Final Conclusion: The earlier order was left undisturbed because no legally recognised ground for review was made out.

Ratio Decidendi: Review is available only for a self-evident error, newly discovered material, or analogous sufficient reason, and cannot be invoked to rehear the case or reargue issues decided on merits.

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