Review jurisdiction limited where petition re-argues merits and certificate defect undermines maintainability.

The Bombay High Court held that a review petition was not maintainable where the Advocate's certificate did not conform to Chapter IV Rule 23(iii) of the Bombay High Court Rules, because the form is meant to ensure counsel accepts responsibility for the review grounds. In any event, the court found no error apparent or other basis for review, as the application largely sought to re-argue matters already decided, including the challenge to the pre-deposit requirement. Because review jurisdiction is limited to narrow grounds and the applicant showed no sufficient case for interference, the petition was dismissed.

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Issues: Whether the review petition was maintainable and whether any ground was made out for exercise of review jurisdiction, including in view of the defect in the Advocate's certificate and the attempt to re-argue the merits.

Analysis: The application for review was accompanied by a certificate that did not conform to the form required under Chapter IV Rule 23(iii) of the Bombay High Court Rules, which is intended to ensure that the Advocate assumes responsibility for the grounds urged in review. Even leaving that defect aside, the grounds advanced did not disclose any error warranting review. The attempt was essentially to reopen the controversy and to press contentions already considered, including the challenge to the pre-deposit requirement. The scope of review jurisdiction being limited, no case was made out for interference.

Conclusion: The review petition was not maintainable on the certificate defect and, in any event, no ground for review was made out; the petition was dismissed.

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