Review jurisdiction limited to patent errors; later reliance on Circular No. 19/2024 could not reopen issues already decided.

Review jurisdiction under Section 114 and Order XLVII Rule 1 CPC is limited to patent errors on the face of the record and cannot be used to reargue matters already considered. The Court held that the earlier order had already proceeded on the basis that the rectification application was filed before the revised Form-2 and while the appeal was pending, and that later reliance on Circular No. 19/2024 did not disclose any self-evident error. The petition therefore amounted only to a request for reconsideration of issues already adjudicated, no error apparent was shown, and the review petition was dismissed.

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Issues: Whether the review petition disclosed any error apparent on the face of the record warranting interference with the earlier order, including on the basis of Circular No. 19/2024.

Analysis: Review jurisdiction under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 is confined to patent errors and cannot be used to reargue matters already considered. The impugned order had already proceeded on the basis that the rectification application was filed before the revised Form-2 and that the appeal was pending, and the later reliance on Circular No. 19/2024 did not establish any self-evident error requiring review. The Court found that the petition merely sought reconsideration of issues already adjudicated.

Conclusion: No error apparent on the face of the record was made out. The review petition was not maintainable in substance and was dismissed.

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