Case Note & Summary
The applicant, Ankita Jagannath Sonawale, a post-graduate law student at Maharashtra National Law University, Chhatrapati Sambhajinagar, was disallowed from appearing in the second/last semester examination for failing to meet the minimum 75% attendance requirement under the Rules of Maharashtra National Law University Regulations 2020. She filed Writ Petition No.4881 of 2026 before the Bombay High Court, Aurangabad Bench, seeking permission to participate in the examination. The writ petition was dismissed by a reasoned order dated 30.04.2026. The examination concluded thereafter. The applicant then filed the present Review Application (Civil) No.95 of 2026 under Order XLVII of the Code of Civil Procedure, 1908, seeking review, recall, or modification of the dismissal order, and also prayed for quashing of the Grievance Redressal Committee's decision dated 28.04.2026, a declaration that the committee's proceedings were arbitrary and violative of natural justice, and a direction to the University to conduct a special examination for her. The Court, after hearing the applicant (party-in-person) and the respondents' counsel, observed that the writ petition was dismissed with a reasoned order and the examination was already over. The Court held that review is not an appeal in disguise and that the applicant failed to point out any error apparent on the face of the record. The Court found no merit in the review application and dismissed it, noting that the applicant was essentially seeking to re-open the matter and obtain a direction for a special examination, which was not permissible in review jurisdiction.
Headnote
A) Civil Procedure - Review Jurisdiction - Order XLVII CPC - Error Apparent on Record - The applicant sought review of dismissal of writ petition challenging denial of permission to appear in semester examination due to shortage of attendance - The Court held that review is not an appeal in disguise and no error apparent on record was shown - The examination having been concluded, no direction for special examination could be granted (Paras 1-5).
Issue of Consideration
Whether the judgment and order dated 30.04.2026 in Writ Petition No.4881 of 2026 suffers from an error apparent on the face of the record warranting review under Order XLVII of the Code of Civil Procedure, 1908.
Final Decision
The Review Application (Civil) No. 95 of 2026 is dismissed. No order as to costs.
Law Points
- Review jurisdiction
- Error apparent on the face of the record
- Order XLVII CPC
- Scope of review
- Attendance requirement
- University regulations
Case Details
Review Application (Civil) No. 95 of 2026 in WP/4881/2026
Smt. Vibha Kankanwadi, Ajit B. Kadethankar
Ms. Ankita Jagannath Sonawale (Party In Person), Mr. S. K. Kadam (Advocate for Respondents)
Ankita Jagannath Sonawale
Maharashtra National Law University, Chh. Sambhajinagar, Through its Registrar; The Vice Chancellor; CPGLS Convenor; Grievance Redressal Committee
Subscribe to unlock Case Details (Citation, Judge, Date & more)
Subscribe Now
Nature of Litigation
Civil review application against dismissal of writ petition challenging denial of permission to appear in semester examination due to attendance shortage.
Remedy Sought
Review, recall, modify or reconsider the judgment dated 30.04.2026; quash decision of Grievance Redressal Committee; declare proceedings arbitrary; direct University to conduct special examination.
Filing Reason
The applicant was disallowed from appearing in the second/last semester examination for not meeting the minimum 75% attendance requirement under the University Regulations 2020.
Previous Decisions
Writ Petition No.4881 of 2026 was dismissed by a reasoned order dated 30.04.2026. The examination concluded thereafter.
Issues
Whether the judgment and order dated 30.04.2026 suffers from an error apparent on the face of the record warranting review under Order XLVII CPC.
Whether the applicant is entitled to a direction for a special examination after the conclusion of the regular examination.
Submissions/Arguments
The applicant argued that the Grievance Redressal Committee's proceedings were arbitrary, mechanical, non-speaking, and violative of natural justice.
The applicant sought review of the dismissal order and direction for a special examination.
The respondents opposed the review application, contending that no error apparent on record was shown and the examination was already over.
Ratio Decidendi
Review under Order XLVII CPC is not an appeal in disguise. The applicant failed to point out any error apparent on the face of the record. The examination having been concluded, no direction for a special examination could be granted in review jurisdiction.
Judgment Excerpts
The applicant has come up with following prayers in this review application : ...
At the outset it needs to be recorded that the Writ Petition was filed for immediate relief in the month of April 2026 for seeking permission to participate in the semester examination. The Writ Petition is dismissed with a reasoned order. The examination is already over.
Procedural History
The applicant filed Writ Petition No.4881 of 2026 seeking permission to appear in the semester examination. The writ petition was dismissed on 30.04.2026. Thereafter, the applicant filed the present Review Application (Civil) No.95 of 2026 under Order XLVII CPC seeking review of the dismissal order and other reliefs. The review application was heard and dismissed on 18.06.2026.
Acts & Sections
- Code of Civil Procedure, 1908: Order XLVII
