Scope of Review Jurisdiction Under Order 47 Rule 1: Alternate Interpretations Do Not Constitute Errors Apparent on Record

sketch of the Bombay High Court
Case
THE STATE OF MAHARASHTRA THROUGH ITS ADD CHIEF SECRETARY v. SUJATA SHRIRAM RATHOD AND OTHERS (Bombay High Court, 01-10-2026)
Law
Administrative Law, Code of Civil Procedure.

Highlights of the Judgment:

  • Examination of the scope and limitations of review jurisdiction under Order 47 Rule 1 and Section 114 of the Code of Civil Procedure, 1908.
  • Judicial interpretation of what constitutes an error apparent on the face of the record versus an error requiring a long-drawn process of reasoning.
  • Application of the principle that a review petition cannot be converted into an appeal in disguise or a rehearing on merits.
  • Analysis of eligibility criteria and educational qualifications stipulated in public service recruitment advertisements.
  • Precedents regarding whether the mere possibility of two differing interpretations of a clause justifies exercising review powers.