Review jurisdiction cannot reopen concluded findings; interest and costs order under the Electricity Supply Code remained undisturbed.

Review jurisdiction is confined to discovery of new and important matter, an error apparent on the face of the record, or other analogous sufficient reason, and cannot be used to reargue concluded issues or substitute for an appeal. Applying that standard, the Court found no reviewable error in the earlier order directing interest on the withheld amount under Clause 10.7.4 of the Jharkhand State Electricity Regulatory Commission (Electricity Supply Code) Regulation, 2015, nor in the costs imposed on the Managing Director. The review petition was therefore held not maintainable on the grounds urged.

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Issues: Whether the review petition disclosed any ground warranting review of the earlier order imposing liability to pay interest on the withheld amount and costs on the Managing Director.

Analysis: The scope of review is confined to discovery of new and important matter, error apparent on the face of the record, or other sufficient reason analogous to those grounds. A review cannot be used to reopen concluded findings or to reargue the matter on the basis that another view is possible. The earlier order had specifically applied Clause 10.7.4 of the Jharkhand State Electricity Regulatory Commission, Ranchi (Electricity Supply Code) Regulation, 2015 to hold that excess withheld amount carried interest from the date of payment till refund or adjustment. The challenge to the costs order also did not disclose any reviewable error, since the grievance amounted only to disputing the correctness of the earlier reasoning. The Court also held that review is not a substitute for appeal and that the impugned directions did not suffer from any patent error justifying interference.

Conclusion: The review petition was not maintainable on the grounds urged and no ground for review was made out.

Ratio Decidendi: Review jurisdiction is limited to patent error, discovery of new material, or analogous sufficient reason, and cannot be invoked to reargue the merits or correct an allegedly wrong but reasoned finding.

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