Order 47, Rule 1 of The Code of Civil Procedure, 1908

The principles for interference in exercise of review jurisdiction are well settled. In Thungabhadra Industries Ltd. v. Government of Andhra Pradesh, AIR 1964 SC 1372 Court while dealing with scope of review had opined:

“A review is by no means an appeal in disguise whereby an erroneous decision is reheard and corrected, but lies only for patent error.”

In Parsion Devi v. Sumitri Devi, (1997) 8 SCC 715 Court after referring to Thungabhadra held thus:

“Judgment may be open to review inter alia if there is a mistake or an error apparent on the face of the record. An error which is not self-evident and has to be detected by a process of reasoning, can hardly be said to be an error apparent on the face of the record justifying Court to exercise its power of review under Order 47, Rule 1.”

An application for review, regard being had to its limited scope, has to be disposed of as expeditiously as possible. Though we do not intend to fix any time limit, it has to be the duty of the Registry of every High Court to place the matter before the concerned Judge/Bench so that the review application can be dealt with in quite promptitude. A reasonable period can be spent for disposal of the review. An endeavor has to be made by High Courts to dispose of the applications for review with expediency. The prescription of limitation for filing an application for review has its own sanctity.”

Hon’ble Justice Dipak MisraSasi v. Aravindakshan Nair, (2017) 4 SCC 692.


Viewed in the backdrop of the factual score in entirety, we are of the considered opinion that decision in Thungabhadra Industries Ltd., (1964) 5 SCR 174 has to be confined to the facts of the said case.”

Hon’ble Justice Dipak Misra, Bussa Overseas and Properties (P) Ltd., (2016) 4 SCC 696.


Also see, S. Madhusudhan Reddy v. V. Narayana Reddy, [Civil Appeal Nos. 5503-04 of 2022] decided on 18.08.2022.