Delay in Review Petitions: long unexplained delay and no error apparent on record, petitions dismissed on delay and merits.

Review petitions were dismissed for both procedural and substantive reasons: the petitions were filed after a long unexplained delay (522 days) and defects noted in the Office Report were not cured, rendering them not maintainable on delay; separately, examination found no error apparent on the face of the record or other recognised ground to meet the substantive threshold for review, so the petitions were dismissed on merits. The ratio states that timely, satisfactorily explained filing and a demonstrable error apparent on the record are prerequisites for entertaining a review.

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Issues: (i) Whether the review petitions filed after a delay of 522 days are maintainable and whether the delay has been satisfactorily explained; (ii) Whether the review petitions disclose any error apparent on the face of the record or any other ground of merit warranting reconsideration of the impugned orders.

Issue (i): Whether the delay of 522 days in filing the review petitions is satisfactorily explained and whether the petitions are maintainable.

Analysis: The review petitions were filed with an unexplained delay of 522 days; defects in the petitions identified in the Office Report remained uncured; the application for listing in open court was rejected. The absence of a satisfactory explanation for the delay and failure to cure the communicated defects were considered in assessing maintainability.

Conclusion: The delay is not satisfactorily explained and the review petitions are not maintainable on the ground of delay.

Issue (ii): Whether the review petitions disclose an error apparent on the face of the record or any merit justifying review.

Analysis: A review requires an error apparent on the face of the record or other recognised grounds; on examination of the petitions, the impugned orders and annexed papers, no such error or merit was found. The petitions therefore do not satisfy the substantive threshold for review even apart from the delay.

Conclusion: The review petitions do not disclose any error apparent on the face of the record or any other merit warranting review and are dismissed on merits.

Final Conclusion: The review petitions are dismissed both for inordinate and unexplained delay and for lack of merit; pending applications are disposed of.

Ratio Decidendi: A review petition must be filed within a reasonably explained time and must demonstrate an error apparent on the face of the record or other recognised grounds; failure to satisfactorily explain delay or to show such an error warrants dismissal of the review.

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