Review Petition in Military Dairy Farm Case Dismissed by Supreme Court

The Supreme Court of India, in the case of Military Dairy Farm, Jabalpur vs. Dhan Prasad Yadav, ruled on a review petition challenging a prior High Court decision regarding an employment dispute. The judgment, delivered by Justices Kurian Joseph and Rohinton Fali Nariman, upheld the High Court’s decision and dismissed the appeal.

Background of the Case

The case pertained to an employment-related dispute involving the Military Dairy Farm in Jabalpur. The appellant challenged the High Court’s order passed in a review petition seeking reconsideration of its judgment dated September 24, 2004, in L.P.A. No. 668 of 2004. The appellant contended that there were errors in the judgment that warranted a fresh review.

The High Court, however, ruled that there was no apparent error in its judgment, and further, subsequent events could not be the basis for reviewing an already decided case. The appellant then approached the Supreme Court, seeking a fresh determination.

Key Legal Issues

• Did the High Court err in rejecting the review petition?
• Can subsequent events be considered a valid ground for review under limited review jurisdiction?
• Should the Supreme Court interfere in a High Court’s review decision?

Arguments of the Parties

Petitioner’s Arguments (Military Dairy Farm, Jabalpur)

The appellant argued that the High Court overlooked key aspects of the case, leading to an erroneous decision. They contended that significant changes had occurred after the judgment, which justified a review.

Respondent’s Arguments (Dhan Prasad Yadav)

The respondent maintained that the High Court had correctly applied the principles of review jurisdiction and that no error was apparent on the face of the record. They asserted that subsequent events could not be a basis for reopening an already decided case.

Supreme Court’s Observations

Justice Kurian Joseph, delivering the judgment, stated:

“We see no error in the approach made by the High Court in the impugned order passed in exercise of its limited review jurisdiction.”

The Court upheld the High Court’s ruling that subsequent developments cannot serve as grounds for a review petition.

Final Verdict

The Supreme Court dismissed the appeal, affirming that the High Court had properly exercised its limited review jurisdiction. The Court concluded that there was no error in the High Court’s decision, and no costs were awarded.

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Download Judgment: Military Dairy Farm, vs Dhan Prasad Yadav Supreme Court of India Judgment Dated 02-03-2016-1741853905946.pdf