Review jurisdiction limited to patent error; fresh facts cannot reopen dismissal of condonation of delay.

Review jurisdiction is confined to the narrow grounds under Order XLVII Rule 1 CPC and cannot be used to reargue the matter, fill gaps in the original pleadings, or introduce facts that were available earlier. The review application failed because it did not disclose an error apparent on the face of the record or any other permissible ground to reopen the order dismissing condonation of delay. The additional factual pleas raised in review were not part of the original condonation application, and the delay after obtaining the certified copy remained unexplained. The order dismissing condonation of delay was therefore left undisturbed.

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Issues: Whether the review application disclosed any error apparent on the face of the record or other permissible ground to reopen the order dismissing condonation of delay.

Analysis: Review jurisdiction is confined to the narrow grounds recognised under Order XLVII Rule 1 of the Code of Civil Procedure, 1908. A review cannot be used to reargue the matter, improve upon the original pleadings, or introduce new facts that were available when the condonation application was filed. The stated grounds did not explain the delay after the certified copy was obtained, and the additional factual pleas raised in review were not part of the original application. The governing principles on condonation of delay also require a proper explanation and do not permit a liberal approach to cure absolute negligence or absence of bona fides.

Conclusion: The review application was not maintainable on the grounds urged and was liable to be rejected.

Final Conclusion: The order dismissing condonation of delay was left undisturbed, and the attempt to reopen it through review failed.

Ratio Decidendi: Review lies only for a patent error or other narrowly permitted ground and cannot be used as a substitute for an appeal or to present a fresh case not pleaded earlier.

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