Supreme Court Dismisses Review Petition in P.S. Patel vs State Bank of Saurashtra
The Supreme Court of India, in its judgment dated March 15, 2022, ruled on the review petition filed by P.S. Patel against the State Bank of Saurashtra. The Court dismissed the review petition, citing that there was no error apparent on record that would justify reconsideration of the matter.
Background of the Case
The case initially arose from a dispute between P.S. Patel and the State Bank of Saurashtra, which led to litigation in the High Court. The Single Judge Bench of the High Court dismissed the Special Civil Application No. 9396 of 1997. The petitioner then approached the Division Bench, which upheld the Single Judge’s decision.
Dissatisfied with the High Court’s ruling, P.S. Patel filed a Special Leave Petition (SLP No. 19787 of 2015) before the Supreme Court. The Supreme Court, after reviewing the case, affirmed the findings of the lower courts and dismissed the SLP.
Subsequently, P.S. Patel filed a review petition, which was also dismissed.
Petitioner’s Arguments (P.S. Patel)
The petitioner, P.S. Patel, contended that:
- The High Court and Supreme Court erred in dismissing the Special Civil Application and the SLP.
- The case required reconsideration due to legal and factual errors.
- The Supreme Court’s ruling contained an error apparent on record, warranting a review.
Respondent’s Arguments (State Bank of Saurashtra)
The respondent, represented by the State Bank of Saurashtra, argued:
- The lower courts had correctly interpreted and applied the law.
- The petitioner was merely attempting to reargue the case rather than pointing out a valid error.
- Review petitions are not meant to reopen settled cases unless there is a manifest error on record.
Supreme Court’s Observations
The Supreme Court, comprising Justices Uday Umesh Lalit and Ajay Rastogi, examined the review petition and ruled:
“The dismissal of Special Civil Application No. 9396 of 1997 by the Single Judge of the High Court was affirmed by the Division Bench, which in turn was under challenge before this Court. Affirming the view taken by the courts below, the Special Leave Petition was dismissed.”
Regarding the review petition, the Court stated:
“The grounds taken in the Review Petition do not make out any error apparent on record to justify interference.”
Final Verdict
The Supreme Court dismissed the review petition, reaffirming its previous decision.
Implications of the Judgment
This ruling reinforces several key principles:
- Review petitions cannot be used as an opportunity to relitigate a matter.
- The Supreme Court does not interfere unless there is a clear and apparent error in the previous judgment.
- Once a case has been examined at multiple levels, including the High Court and Supreme Court, further review is unlikely unless exceptional circumstances exist.
Conclusion
The Supreme Court’s ruling in P.S. Patel vs. State Bank of Saurashtra reaffirms that review petitions are limited in scope. The judgment serves as a precedent for future cases, emphasizing that parties should not seek review simply to challenge unfavorable verdicts without substantial justification.
Petitioner Name: P.S. Patel.
Respondent Name: State Bank of Saurashtra.
Judgment By: Justice Uday Umesh Lalit, Justice Ajay Rastogi.
Place Of Incident: India.
Judgment Date: 15-03-2022.
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