Writ review jurisdiction is limited to CPC-like grounds and cannot reopen merits with documents that could have been produced earlier.

Review of a writ order under Article 226 is available only on grounds analogous to Order 47 Rule 1 CPC, including discovery of new and important matter despite due diligence, error apparent on the face of the record, or similar grounds. The power exists to prevent miscarriage of justice and correct grave errors, but it cannot be used as a substitute for appeal or to reargue the merits. Where additional documents were not shown to have been unavailable at the time of the writ hearing and no due diligence explanation was offered, review was not justified. In such circumstances, no apparent error on the record was made out and the review petition was liable to be dismissed.

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Issues: Whether the High Court could review its writ order on the basis of additional documents not shown to have been unavailable earlier, and whether any error apparent on the face of the record was made out.

Analysis: The review jurisdiction under Article 226 is not barred in principle, but it is confined to grounds analogous to those in Order 47 Rule 1 of the Code of Civil Procedure, namely discovery of new and important matter despite due diligence, error apparent on the face of the record, or like analogous grounds. The power is inherent in a court of record to prevent miscarriage of justice or correct grave and palpable errors, but it cannot be used as a substitute for appeal or to reargue the matter on merits. The additional documents relied upon were not shown to have been unavailable when the writ proceedings were heard, and no explanation was offered to satisfy the requirement of due diligence.

Conclusion: No ground for review was made out, and the review petition was liable to be dismissed.

Final Conclusion: Review jurisdiction was not available to reopen the writ order on the basis of documents that could have been produced earlier, and the challenge failed for want of any apparent error on the record.

Ratio Decidendi: A writ order may be reviewed only on grounds analogous to Order 47 Rule 1 of the Code of Civil Procedure, and additional material not shown to have been unavailable despite due diligence cannot justify review in the absence of an error apparent on the face of the record.

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