Review jurisdiction cannot reopen final judgments merely because later precedent changed or applications are dressed as recall requests.

Review jurisdiction under Article 137, read with Section 114 and Order XLVII Rule 1 CPC, is confined to recognised legal grounds and cannot be invoked merely because an earlier precedent has later been overruled or recalled. An order that was correct when made does not become reviewable due to a subsequent change in law, and an earlier reference to "liberty" does not create a general right to reopen concluded matters. Applications styled as clarification, modification or recall will be treated according to their substance; if they seek reconsideration of a final order, they remain barred. Inherent powers under Section 151 CPC and Article 142 cannot be used to create a review jurisdiction.

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Issues: (i) Whether review petitions could be entertained on the basis that an earlier precedent had been subsequently overruled or recalled and on the strength of the alleged "liberty" said to be contained in an earlier judgment; (ii) whether miscellaneous applications styled as clarification, modification or recall applications were maintainable when they were, in substance, attempts to seek review of final orders.

Issue (i): Whether review petitions could be entertained on the basis that an earlier precedent had been subsequently overruled or recalled and on the strength of the alleged "liberty" said to be contained in an earlier judgment.

Analysis: The power of review under Article 137 of the Constitution of India read with Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 is narrowly confined to the grounds recognized by law. The Explanation to Rule 1 of Order XLVII expressly bars review merely because the legal position has since been reversed or modified in another case. A judgment that was correct when rendered does not become reviewable because of a subsequent change in law. The alleged "liberty" in the earlier decision was not construed as a carte blanche to reopen finally concluded matters behind the back of affected parties, and a co-equal Bench could not treat that observation as creating a general right to seek review on the basis of later developments. The grounds urged were held to fall outside the permissible scope of review.

Conclusion: The review petitions were not maintainable on the basis of the subsequent overruling or recall of the earlier precedent, and the contention founded on the alleged liberty was rejected.

Issue (ii): Whether miscellaneous applications styled as clarification, modification or recall applications were maintainable when they were, in substance, attempts to seek review of final orders.

Analysis: Applications cannot be allowed to bypass the statutory discipline governing review by being dressed up as miscellaneous, clarification or recall requests. Where the substance of the application is reconsideration of a concluded judgment or order, the Court will treat it according to its true nature. The inherent powers preserved by Section 151 of the Code of Civil Procedure, 1908 and the power under Article 142 of the Constitution of India cannot be used to create a review jurisdiction where the statute does not permit one. Finality of judicial determinations and the legislative bar in the Explanation to Order XLVII Rule 1 cannot be circumvented by nomenclature.

Conclusion: The miscellaneous applications were held not maintainable.

Final Conclusion: The reference was answered against reopening the final judgments through review or disguised review applications, while limited remand and consequential directions were issued in selected matters under the Court's constitutional powers.

Ratio Decidendi: A final judgment cannot be reviewed merely because the legal position has later changed by overruling or recall of the precedent on which it was based, and applications in substance seeking such reconsideration remain barred notwithstanding their label or the invocation of inherent powers.

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