Review jurisdiction cannot reopen merits absent patent error or new material; earlier adjudication directions were upheld.

Review jurisdiction is limited to discovery of new and important matter, error apparent on the face of the record, or analogous sufficient cause under Order XLVII Rule 1 CPC, and cannot be used to reargue concluded merits. Applying that standard, no manifest mistake or patent error was shown in the earlier order directing supply of original non-relied documents and continuation of adjudication, so interference was unwarranted and the review petition was rejected.

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Issues: Whether the review petition disclosed any error apparent on the face of the record or other ground warranting interference with the earlier order directing supply of original non-relied documents and permitting adjudication to proceed.

Analysis: Review jurisdiction is confined to the grounds recognised under Order XLVII Rule 1 of the Code of Civil Procedure, 1908, namely discovery of new and important matter, error apparent on the face of the record, or analogous sufficient reason. A review cannot be used to reargue the merits or to obtain rehearing of a concluded matter. Applying that settled standard, the earlier order was found to be supported by the governing statutory provisions and binding precedent, and no manifest mistake or patent error was shown to justify reopening it.

Conclusion: No ground for review was made out; the earlier directions were maintained.

Final Conclusion: The review petition was rejected and the adjudication directions in the earlier order were left undisturbed.

Ratio Decidendi: Review lies only for a patent error, discovery of new material, or analogous sufficient cause, and cannot be employed as an appeal in disguise to revisit a decision on merits.

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