Limited review jurisdiction does not reopen merits; questions on an IRP report's evidentiary value may remain for the competent tribunal.

Review jurisdiction under Section 114, Order XLVII Rule 1 and Section 151 CPC is limited to correcting an error apparent on the face of the record and cannot be used to re-argue the merits of an earlier order. The text states that the impugned observations did not treat the IRP report as without legal effect and did not bar its consideration in appropriate proceedings. Questions on the report's legality, veracity, probative value, and the scope of the IRP's actions under the Insolvency and Bankruptcy Code, 2016 were said to lie within the NCLT's domain, which was already seized of the matter. The earlier observations were therefore not shown to warrant review.

---

---

Issues: Whether the review petition disclosed any error apparent on the face of the record warranting review of the earlier order, including the prayer to clarify that the IRP report dated 09.08.2023 was not to be treated as useless or devoid of legal effect.

Analysis: The review power under Section 114, Order XLVII Rule 1 and Section 151 of the Code of Civil Procedure, 1908 is confined to correction of an error apparent on the face of the record and cannot be used to re-argue the merits of the earlier decision. The impugned observations, read as a whole, did not declare the IRP report to be a waste paper, nor did they preclude its consideration in appropriate proceedings. The Court also noted that the legality, veracity and probative value of the IRP report, including matters concerning the scope of the IRP's actions under the Insolvency and Bankruptcy Code, 2016, fell within the domain of the NCLT, which was already seized of the matter. The earlier observations concerning investigation under the Companies Act, 2013 were therefore not shown to suffer from any apparent error requiring review.

Conclusion: The review petition did not merit interference on the ground of any apparent error, and the limited clarification recorded by the Court did not justify reopening the earlier order.

Final Conclusion: The review jurisdiction was not invoked successfully, and the earlier order remained undisturbed.

Ratio Decidendi: Review is not maintainable to revisit or reinterpret concluded findings unless a clear error apparent on the face of the record is demonstrated; questions concerning the evidentiary worth and legality of an IRP report may be left to the competent tribunal exercising substantive jurisdiction.

---