Case Note & Summary
The petitioner, V.Arun Kumar, filed a review petition (REV.APLW No. 77 of 2026) before the Madras High Court seeking to review the order dated 31.7.2024 passed in WP No.14812 of 2024. The writ petition had challenged the recruitment process conducted by the Tamil Nadu Public Service Commission (TNPSC) for the post of Civil Judge. The review petitioner contended that the order suffered from errors apparent on the face of the record. The respondents, including the State of Tamil Nadu, TNPSC, the Registrar General of the High Court, and three impleaded parties, opposed the review. The court, comprising Justice S.M. Subramaniam and Justice C. Kumarappan, examined the scope of review jurisdiction under Order 47 Rule 1 of the Code of Civil Procedure, 1908. The court noted that review is not an appeal in disguise and is limited to correcting errors apparent on the face of the record. The petitioner failed to demonstrate any such error. The court found that the review petition was devoid of merits and dismissed it, along with the connected miscellaneous petition. The judgment was delivered on 17-04-2026 and uploaded on 24-04-2026.
Headnote
A) Civil Procedure - Review - Order 47 Rule 1 Code of Civil Procedure, 1908 - Error Apparent on Record - The petitioner sought review of an order dismissing his writ petition challenging TNPSC recruitment process - The court held that review is not an appeal in disguise and the petitioner failed to point out any error apparent on the face of the record - The review petition was dismissed as devoid of merits (Paras 1-6).
Issue of Consideration
Whether the order dated 31.7.2024 in WP No.14812 of 2024 suffers from any error apparent on the face of the record warranting review.
Final Decision
The review petition (REV.APLW No. 77 of 2026) and the connected miscellaneous petition (WMP No. 17385 of 2026) are dismissed as devoid of merits.
Law Points
- Review jurisdiction is limited to errors apparent on the face of the record
- not re-argument of the case
- Order 47 Rule 1 CPC
