Haridas Das v. Usha Rani Banik, (2006) 4 SCC 78 while reiterating decisions in Aribam Tuleshwar Sharma v. Aribam Pishak Sharma, (1979) 4 SCC 389 and Meera Bhanja v. Nirmala Kumari Choudhury, (1995) 1 SCC 170 drew out narrow contours within which review jurisdiction of this Court had to be exercised and held, Order XLVII, CPC does not allow for rehearing of a dispute merely because a party had not highlighted all aspects of a case.

When ground for review sought is discovery of new evidence, State of West Bengal v. Kamal Sengupta, (2008) 8 SCC 612 clarified, same must be evidence which should be materially important to decision taken.

M. Lingamaiah had urged grounds of review numbered in excess of 90. The general impression is, more the number of grounds, less the likelihood of existence of a case for review. However, disabusing our mind of such an impression, we have looked into each one. Not a single ground deserved consideration to embark on an exercise to review even on basis of discovery of new and important matter or evidence. We are constrained to observe, there has been usurpation of power by Review-Division Bench to overturn a well-considered and well-crafted decision of Original-Division Bench.

– Hon’ble Justice Dipankar Datta, S. Tirupathi Rao v. M. Lingamaiah, [Special Leave Petition (Civil) Nos. 19647-48 of 2022] decided on 22.07.2024.

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In summing up precedents, the Judgment may not be understood as though we are putting an old spin on a classic.

– Hon’ble Justice S.V.N. Bhatti, Malleeswari v. K. Suguna, [Special Leave Petition (Civil) No. 12787 of 2025] decided on 08.09.2025.