Supreme Court Rejects Review Petition, Upholds Previous Ruling on Legal Interpretation Without Oral Hearing

SC dismissed review petition, rejecting oral hearing despite condoning delay. Court disagreed with prior three-Judge Bench decision in Ganpati Dealcom case, relying on K.L. Rathi Steels Limited ruling. The Court interpreted CPC Order XLVII Rule 1 Explanation, holding that reversal of legal interpretation in another case does not constitute grounds for review. Review petition was dismissed with pending applications disposed of.

---

---

The Supreme Court, through Hon'ble Justices B. V. Nagarathna and Augustine George Masih, dismissed the Review Petition, condoning delay but rejecting the application for oral hearing. The Court expressly disagreed with a prior three-Judge Bench decision in Union of India vs. M/s Ganpati Dealcom Pvt. Ltd. that had granted liberty to seek review based on reliance on that judgment.The Court relied on an earlier three-Judge Bench ruling in Government of NCT of Delhi vs. K.L. Rathi Steels Limited [(2024) 7 SCC 315], which interpreted the Explanation to Rule 1 of Order XLVII of the Code of Civil Procedure, 1908. This provision clarifies that "The fact that the decision on a question of law on which the judgment of the Court is based has been reversed or modified by the subsequent decision of a superior Court in any other case, shall not be a ground for the review of such judgment."Since the Ganpati Dealcom Bench failed to consider the binding and prior decision in K.L. Rathi Steels Limited, the present Bench declined to grant liberty for review. The Review Petition was therefore dismissed, with all pending applications disposed of.

---