Review Petition Dismissed: Supreme Court Upholds Punjab Land Revenue Order

The Supreme Court of India recently dismissed a review petition in the case of Joginder Singh and Another vs. State of Punjab & Others. The judgment reaffirmed the view taken by the Punjab and Haryana High Court regarding a dispute under the Punjab Land Revenue Act. The petitioners had sought a review of the Supreme Court’s previous order dismissing their special leave petition, but the Court found no “error apparent on record” to justify reconsideration.

Background of the Case

The dispute arose when the Collector passed an order that was later affirmed by the Financial Commissioner in revision. Dissatisfied with the outcome, the petitioners filed a writ petition before a Single Judge of the Punjab and Haryana High Court, challenging the legality of the Collector’s order. When the Single Judge ruled against them, the petitioners pursued a Letters Patent Appeal (LPA), which was also rejected by the High Court.

With no relief from the High Court, the petitioners approached the Supreme Court through a Special Leave Petition (SLP). However, after hearing the arguments, the Supreme Court dismissed the SLP, thereby upholding the High Court’s decision.

Seeking a reconsideration of the Supreme Court’s order, the petitioners filed a review petition (Review Petition Civil No. 267 of 2022), arguing that the decision suffered from an “error apparent on the record.”

Key Legal Issues Considered

Whether the review petition disclosed any “error apparent on the record.”
Whether the Supreme Court had overlooked any crucial legal or factual issues while dismissing the SLP.
Whether the High Court’s interpretation of the Punjab Land Revenue Act was erroneous.

Petitioner’s Arguments (Joginder Singh & Another)

The Collector’s order was contrary to law and should have been set aside by the High Court.
The Financial Commissioner and the High Court erred in failing to appreciate the factual and legal grounds raised.
The Letters Patent Appeal was wrongly dismissed, denying them a fair hearing.
The Supreme Court’s order dismissing their SLP contained errors that warranted review.

Respondent’s Arguments (State of Punjab & Others)

The petitioners had already exhausted all available legal remedies, and their claims had been thoroughly examined at multiple levels.
The Collector’s order was passed in accordance with the provisions of the Punjab Land Revenue Act.
There was no error apparent in the Supreme Court’s prior ruling dismissing the SLP.
Review petitions are not an avenue for re-arguing a case but are limited to correcting manifest errors.

Supreme Court’s Observations

The Court noted that the Collector’s order had been upheld by multiple appellate authorities, including the Financial Commissioner and the High Court.
The petitioners failed to establish any “error apparent on the record” that would justify a review of the Supreme Court’s earlier order.
The review petition did not raise any new legal issues but merely sought to reargue matters already settled.

The Court stated:

“We have gone through the grounds taken in the review petition, which do not make out any error apparent on record. This review petition is, therefore, dismissed.”

Final Judgment

The review petition was dismissed.
The Supreme Court reaffirmed its previous order dismissing the Special Leave Petition.
The ruling of the Punjab and Haryana High Court, which upheld the Collector’s order, remained undisturbed.

Key Takeaways from the Judgment

Review petitions must demonstrate clear errors: The Supreme Court reaffirmed that review petitions should not be used to reargue a case but must highlight manifest errors.
Limited scope of review jurisdiction: The Court clarified that unless there is an “error apparent on record,” a review petition cannot be entertained.
Finality of judicial decisions: The dismissal of the review petition confirms that once the Supreme Court has decided a matter, subsequent challenges are unlikely to succeed unless substantial legal errors are identified.

Conclusion

This ruling underscores the principle that review petitions are an exceptional remedy and cannot be used as an opportunity to revisit issues already settled by the Court. The judgment sets a precedent that litigants must present strong, clear legal grounds before seeking a review of the Supreme Court’s decisions.

Petitioner Name: Joginder Singh & Another.
Respondent Name: State of Punjab & Others.
Judgment By: Justice Uday Umesh Lalit, Justice S. Ravindra Bhat.
Place Of Incident: Punjab.
Judgment Date: 03-03-2022.

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