DR.

RAM MANOHAR LOHIYA

NATIONAL LAW UNIVERSITY, LUCKNOW

REVIEW UNDER CPC: ANALYSIS OF THE UNDERLYING JUDICIAL

POLICY

SUBMITTED TO- SUBMITTED BY-

Dr. Vipul Vinod Chanchal Verma
Associate Professor Enrol no.- 220101058
Code of Civil Procedure 4th Semester, 2nd Year
Dr. Ram Manohar Lohiya B.A. LL.B. (Hons.)
National Law University, Lucknow

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ACKNOWLEDGEMENT
I would like to express my gratitude towards all those whose help and constant support the
project would not have reached its current facet. Foremost, I would like to thank DR. VIPUL
VINOD for her kind guidance and for quenching my queries on many doubts and
technicalities that I came up with during the making of this project. I would take advantage of
this situation to thank him for providing me with such an enriching opportunity to work and
research on this topic.
This project would not have seen the light of day without the constant direction and guidance
of my parents and guardians, to whom I owe a lot. I would also like to use this opportunity to
thank my seniors for helping me out with the nitty-gritty of formatting.
I would also like to thank all of my friends who aided me along the way. I must also extend
my gratitude to the library and library personnel who provided me with research material and
good books to work on and the distinguished authors, jurists, and journals for providing in the
public domain such invaluable information.

Thank you,
CHANCHAL VERMA
PRACTICAL IMPLICATIONS OF REVIEW
1. Correction of Errors:
The primary purpose of review is to rectify mistakes made in court decisions.
If an error is apparent on the face of the record (such as a calculation error
or misinterpretation of law), review allows for correction.
2. Balancing Finality and Justice:
While court decisions are generally considered final, the review process
strikes a balance.
It ensures that justice prevails even if it means revisiting a decision.
3. Judicial Accountability:
The review holds judges accountable for their decisions.
It prevents arbitrary or unjust outcomes by allowing reconsideration.
4. Legal Certainty vs. Flexibility:
Finality provides legal certainty, but it must not hinder justice.
The review introduces flexibility without undermining stability.
5. Public Confidence:
A transparent and fair review process maintains public confidence in the
legal system.
Correcting errors reinforces trust in the judiciary.
6. Limited Scope:
Review is not a full re-hearing; it focuses on specific grounds.
This limitation prevents abuse and ensures efficiency.
7. Impact on Litigants:
Successful review can alter the outcome of a case, affecting parties’ rights
and obligations.
Unsuccessful review may lead to acceptance of the original decision.
In summary, the practical implications of review extend beyond legal
technicalities—they impact justice, trust, and the overall functioning of the
legal system.

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DECLARATION
I hereby declare that the project title, Review under CPC: Analysis of the Underlying Judicial
Policy, submitted by me to Dr. Ram Manohar Lohiya National Law University, Lucknow, in
partial fulfillment, is required for the award of the degree of B.A. LL.B. (Hons.) is a record of
bonfide project work carried out by me under the guidance of Dr. Vipul Vinod (Associate
Professor, Law).
I further report the work reported in the project has not been submitted and will not be
submitted, either in part or in full, for the award of any other degree or diploma in this
institute or any other institute or university.
CHANCHAL VERMA
ENROLLMENT NO.- 220101058
FOURTH SEMESTER B.A. LL.B.(Hons.)
DR. RAM MANOHAR LOHIYA NATIONAL LAW UNIVERSITY, LUCKNOW
CODE OF CIVIL PROCEDURE

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TABLE OF CONTENTS
ACKNOWLEDGEMENT……………………………………………………………2
DECLARATION……………………………………………………………………...3
TABLE OF CONTENTS…………………………………………………………….4
ABSTRACT…………………………………………………………………………5
INTRODUCTION……………………………………………………………………5
REVIEW UNDER CIVIL PROCEDURE CODE……………………………………6
a) Who may apply for review?..............................................................................6
b) When does review lies?......................................................................................6
c) By whom review may be made?..........................................................................6
d) Form of Application…………………………………………………………….6
e) Procedure at hearing…………………………………………………………….7
f) Limitation…………………………………………………………………………7
g) Review (writ petitions) …………………………………………………………….7
h) Review by Supreme Court………………………………………………………….7
GROUNDS FOR APPLICATION OF REVIEW………………………………………...8
a) Discovery of New Evidence…………………………………………………….8
b) Error apparent on the face of the record………………………………………...8
c) Other Sufficient Reason………………………………………………………….8
RELATION OF REVIEW WITH REFERENCE, APPEAL AND REVISION………….9
a) Review and Reference…………………………………………………………….9
b) Review and Appeal……………………………………………………………………9
c) Review and Revision……………………………………………………………….10
JUDICIAL PRECEDENTS………………………………………………………………...11
CONCLUSION…………………………………………………………………………….12
BIBLIOGRAPHY……………………………………………………………………………13
a) Constitution………………………………………………………………………...13
b) Statutes……………………………………………………………………………...13
c) Books……………………………………………………………………………….13
d) Case Cited……………………………………………………………………………13

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ABSTRACT
The paper focuses on the judicial policy that underlies the review process under the CPC. The
review process is an exception to the general rule that once the court has rendered a judgment
and signed it, it no longer has jurisdiction to modify it and it loses control over it. The authors
have conducted an analysis to determine when a review can be sought and who can make it.
The paper also delves into the grounds on which a review can be sought and highlights that
our judicial system is designed to rectify any errors made in the course of the judgment. The
paper identifies four ways in which an aggrieved party can seek an appeal against the decree,
file an application for review or reference, or in some cases, a subordinate court can make
references to the High Court. This is why the authors have analyzed the differences between
Review, Revision, Reference, and Appeal. The authors have also analyzed judicial precedents
in relation to review and judicial opinions on the review procedure.
KEYWORDS: REVIEW; REVISION; REFERENCE; APPEAL.

INTRODUCTION
Review is an exception to the rule that once the court has pronounced the judgment and
signed, it has no jurisdiction to alter it and it ceases to have control over it. The power of
review in civil cases is derived from section 114 of the Civil Procedure Code, while Order 47
of CPC provides for the procedure of Review. The general principle is that once the court has
decided on a particular case, the court becomes functus officio, which means that such a
judgment is final and that it cannot be changed. Review is a very reluctant step by the court,
and it is called only when there is a serious error or some omission in the judgment.1 The
power of Review is different from that of appellate powers; in an appeal, the power is given
to the appellate court to correct errors committed by the subordinate court.2 In Review, the
case is again decided by the same court. A review case is not equal to that of the original case,
and the case cannot be reopened or reconsidered, or the decision cannot be changed until the
court is sure that they have committed a grave error. To review a case that has already been
decided is a waste of time if no error is found. If the review application is not maintainable
before the court, then it cannot be described as an application for clarification or
modification.3 The right to review is a substantive as well as a procedural right. It is not an
inherent right and has to be expressly conferred by law. A procedural law, the court can
correct any defect, misrepresentation, or fraud of a party. Review means reconsideration of
the judgment by the same court; in some countries, in place of review, there is a writ of error.
The philosophy behind this doctrine of review is that due to an error committed by a human
being, justice should not suffer. Justice should prevail at any cost.4

1
C.K Takwani, Civil Procedure and Limitation, 8th Edition, 2019
2
Lily Thomas v. Union of India, (2000) 6 SCC 224.
3
Delhi Admn. v. Gurdip Singh Uban, (2000) 7 SCC 296.
4
Common Cause, A Registered Society v. Union of India, (1999) 6 SCC 667.

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REVIEW UNDER CIVIL PROCEDURAL CODE
WHO MAY APPLY FOR REVIEW?
The application for the review of the judgement can be filed by the aggrieved party against
whom the order or decree of court has been passed. There is no definition of an aggrieved
party and it is an elusive concept. The term aggrieved party in the common use means the
party against whom the decree or an order has been passed. The aggrieved party can file an
application for review of the judgment if they feel that the judgment has been wrongfully
pronounced.5 The term person aggrieved is not conclusive and sometimes the term “party
aggrieved” has been used. A person who not a party to the judgment and he is not affected by
the decree, he cannot apply for review. The third party can only apply for review if it has
been affected by the order passed by the court.6
WHEN DOES REVIEW LIES?
1. A decree or order is open to review if no appeal is allowed. When an appeal is
dismissed because it is time-barred or it was incompetent, the party can file for
review.
2. In case where appeal lies but is not preferred, appeal is also available to the aggrieved
party the review petition is maintainable, the fact that if an order can be appealed in
the higher court is not a ground to reject an application for review. The application for
review can be filed if no appeal has been instituted, however if the appeal has already
been filed before the review application, the court will not allow the review
application. If the higher court dismisses the appeal no review can be filed in the
lower court. However, in cases where the appeal is filed after the review the
jurisdiction of the court deciding the review will not be affected. If the court allows
review before the disposal of appeal, the decree will not be allowed, and appeal will
not be allowed. In case where appeal is decided on merits before the review
application, such petition will be dismissed.
3. The CPC allows review of the judgement on a reference from the small causes court.7
BY WHOM REVIEW MAY BE MADE?
Review is reconsideration of the same judgment that has been passed by the same court and if
possible, by the same judge, if the same judge is available then he has the jurisdiction to
decide the case again and review it. The reason behind this is that the judge will remember
the arguments that were contended before him and what was not. Therefore, it is best suited
that he should review the decision because he is best suited to remove any error made in his
own judgment. However, in cases where it is not possible for the judge who gave the
judgment to review it then his successor or any other judge of same jurisdiction may decide
the case.
FORM OF APPLICATION

5
Jasbhai Motibhai v. Roshan Kumar, (1976) 1 SCC 671.
6
Shivdeo Singh v. State of Punjab, AIR 1963 SC 1909.
7
Order 47 Rule 1(1)(c), Civil Procedure code, 1908.

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The application of review should be a memorandum of application; however, form of
application is immaterial. What the substance of application is more important.
PROCEDURE AT HEARING
In the first stage the application commences ex-parte by the aggrieved party, the court after
looking into the application may reject the application or accept it and call the other party to
show why review should not take place.8 In the second stage the application of review shall
be heard again by the same court and if the rule is discharged, then the application will be
dismissed, while if the rule is made absolute then the matter will be heard again.9 In the third
stage the case will be decided on the merits, the court after deciding the case may grant the
original decree or vary it.18 Any order that will be made by the court which modifies the
decree or reverses it, then a new decree will be passed which will supersede the previous
one.10
LIMITATION
The application for review of a judgment should be made within 30 days from the date of the
decree or order other than that in the supreme court.11
REVIEW (WRIT PETITIONS)
The provisions of Order 47 do not apply to the writ petitions under Article 226 that are filed
in the High Court, due to the amendment in Section 141 of Civil Procedure Code. Nothing in
Article 226 can prevent the High Court from exercising the power of review. The High Court
can review a judgment and erase a possible error that might have occurred. However, there
are certain defined limits to exercise the power of review. The High Court has the power to
review under Article 226 of the Constitution and Order 47 does not apply to the power of
review of the High Court. This power of review should be utilized by the High Court if there
is a miscarriage of justice.12
REVIEW BY SUPREME COURT
Article 137 of the Constitution confers the power to the Supreme Court to review judgments
subject to any laws or rules made by the parliament under Article 145. The Civil procedure
code cannot curtail the power of Supreme Court.13

8
Order 47 R. 4(1), Civil Procedure Code 1908.
9
Order 47 R. 4(2), Civil Procedure Code 1908.
10
Order 47 R. 8, Civil Procedure Code 1908.
11
Art. 124, Limitation Act, 1963.
12
Gujarat University v. Sonal P. Shah, AIR 1982 Guj 58.
13
Art. 137, Constitution of India, Or. 40, Supreme Court Rules, 1966.

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GROUNDS FOR APPLICATION OF REVIEW
Application for review can be made following grounds:
DISCOVERY OF NEW EVIDENCE
An application for review can be filed by the applicant if there is a discovery of some new
evidence which was not possible to present at the time the decree was passed.14 It is a general
rule that the decree passed will not be overturned until there is a very strong reason to do so.
So, when the ground of new evidence is the reason for review of judgment utmost care is
taken. The party who lost the case will try their best to collect evidence on the weak points of
the case by trying to find evidence and change the case in the favor of the party that lost. The
party who has filed for review must show that there was proper care taken while adducing
evidence at the trial, and that the new evidence should be conclusive in nature or of such a
nature that it would change the decision of the court. In the case where the evidence could
have been produced at earlier stage and reasonable care could have been taken the application
for review will be refused.
ERROR APPARENT ON THE FACE OF RECORD
Error apparent on the face of record is another ground for review. Error should be determined
by examining the case on the facts. If the error is not self-evident and requires examination,
then it will not be termed as error apparent on the face of record. The error which need a long
process of consideration of all the law points then it will not be termed as error apparent on
the face of record.15 Reasons like non-consideration of a statutory provision or omission of a
material issue or when the amendment in law took place retrospectively these reasons will not
be termed as error apparent on the face of record. The Explanation to Order 47 Rule 1 states
that if the question of law on which the judgment is based and if it has been reversed in the
subsequent judgment will not be ground to review the judgment.
OTHER SUFFIECIENT REASON
The phrase “sufficient reason” isn’t defined anywhere. But reasons like when the judgment
has been passed under some misapprehension of circumstances or when the party was not
provided with the opportunity to produce the evidence or when the court has failed to
consider some important issue or if the court has failed to consider any statutory provision,
these will be considered sufficient reasons while, reasons like or absence of the party on the
date of the hearing; or subsequent events; or failure of a party or his pleader to raise a plea or
the case was mismanaged by his counsel or there was different view taken by the court in the
subsequent case, these will not be considered as sufficient reasons.

14
Nundo Lal v. Punchanon Mukherjee, AIR 1918 Cal 618.
15
Thungabhadra Industries Ltd. v. Govt. of A.P, AIR 1964 SC 1372.

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RELATION OF REVIEW WITH REFERENCE, APPEAL AND REVISION
The judges who give the judgments have basic human nature and a human nature is bound to
make mistakes some time or the other. For that reason, our judicial system is designed in such
a way that any such error made in the course of judgment can be rectified. There are 4 ways
in which even after a judgment is passed, the aggrieved party who feel that justice has
wrongly been given, can ask for an appeal against the decree, file an application of review or
reference or in some cases, a subordinate court can make references to the High Court.
REVIEW AND REFERENCE
These two procedures deal with bringing fairness to the legal system. Reference has been
mentioned under section 113 and Order 46 of the Civil Procedure Code whereas right to
review is given under section 114 and Order 47. Even though both the procedures are under
the same judicial system, both are very different from each other. Under both of them, the
main difference is that under reference, a subordinate court seeks clarification from the High
court when there is a question of validity of judgment. Whereas in review, it is the aggrieved
party which asks for re examination of the case.
Every court case is different and it is not possible to have a unified solution for all of them.
That is why it is important in some cases to get clarification from Higher Courts before
passing out any judgment on a particular case. It is primarily done to avoid errors and in this,
the High Court has the right to interpret the legislative provision. But it is to see that not
every case can go for reference to the High Court. There are some requirements which have
to be kept in mind. The case can be referred only by a civil judicature or by an appeal of a
party under „suo moto‟ process. However, when you look at review, the process is done in
the same court where a judge itself re evaluates new evidence and errors which happened in
the legal process. It allows re-correction of human error during the course of judgment so that
an innocent person doesn‟t pay the price.
The key differences which arises between reference and review is that through reference, the
subordinate court asks for clarification from the High Court for any provision under law.
Under review, the party seeks justice in the same court which gave the judgment. Reference
is just a communication between the subordinate court and high court. Review petition is
done when there is a petition for re-examine if there is a newly appeared evidence or error in
the previous case. Ground for reference arises on the question of validity of the provision of
an act, ordinance or regulation. Ground for review arises on discovery of new evidence or
any other reason which deems to be satisfactory. Lastly, the proceeding of reference can start
even when there is pendency of case. It has to be done before a judgment or decree is passed.
However, the process of review petition can only begin when the judge had already passed a
judgment or decree against the party who is aggrieved.
REVIEW AND APPEAL
Under the judicial system, the higher courts have appellate jurisdiction under which the cases
are re-examined. However, in some cases where the appeal is not given to the parties, the
Civil Procedure Code has introduced the concept of review in these matters. In the case of
Usha Ranee Banik vs Hardas16, it was seen that the concept of review shall arise only when

16
Usha Ranee Banik vs Hardas , AIR 2005 Gau 1.

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there is a mistake which is apparent on the record and not on any inaccurate call. Appeal is
given from section 96 to 112 of CPC for civil cases. The actual term „appeal‟ isn’t defined
anywhere. It is termed as the power of the higher authorities or higher court to re-examine the
judgment given by the lower authorities or lower court. It cannot be said as inherent right but
as statutory right. It is the re-hearing of the whole case/dispute in the higher court. The power
of both appeal and review of the court are in accordance to the circumstances of the case and
are applied in the court in different manner and different criterion. To rightly point out the
distinction between the two, review, in basic terms means to reconsider, to look again into the
matter which is done by the same judge in the same court. An appeal petition requires an
application to be filed to the Higher Court for considering or looking into the decision given
by the lower court. Where a review is made merely to rectify any error which has been made
in the interest of the party, the appellate courts re-examine the questions of facts and law and
even look into the evidences presented in the case all over again. As mentioned above, it is
important for discovery of a new valid matter for the case to go under review or there has to
be error in judgment or any other sufficient reason. On the other hand, the grounds of appeal
are such that the case should have already been decided in the subordinate court and not
pending in the high court. Any person, whose name has been entered into the suit and is a
party to the suit, has been adversely by the decree given in the suit can file for an appeal
petition in the higher court. Lastly, when any person is bound by a decree which would
operate res judicata against him. The review petition can be filed by the aggrieved party when
he does not have the right to appeal.
REVIEW AND REVISION
The term has not been per say „defined‟ in the Civil Procedure Code but has been mentioned
under section 115 of the CPC. It is the power of the court to revise the cases which has
already been decided by the subordinate courts. This jurisdiction which the high court have is
known as „Revisional Jurisdiction‟ of High Court. For a revisional jurisdiction to be applied,
the case has to be decided by the lower court and no appeal should have been exercised. In
the case of Major S.S Khanna vs Brig F.J Dillion17, it was held by the Supreme Court that if
there is availability of any other remedy, revisional jurisdiction shall not be exercised.
As mentioned before, both of these powers are mentioned in different provisions of CPC.
Where review is just re-examining the case in the same court in front of the same judge,
revision means that the higher court shall revise the judgment of any case which has been
decided by the subordinate or lower court. It is done with the view of correcting a judgment
which the higher court deems fit. Revision mostly deals with any illegality or irregularity
which comes to the notice of the High court and examine the records and proceeding which
can be corrected by the High Court. The provision dealing with both review and revision are
mentioned under section 114 and section 115 of the CPC respectively. For the provision of
revision to be applied, the case necessarily has to be decided by the subordinate court and no
appeal for that case should be pending in the High court. It should also be seen that
subordinate or lower court, while deciding the case, 1) must have exercised some jurisdiction
which is not mentioned under law 2) have failed to exercise the jurisdiction it has been vested
with and 3) the lower court has exercised its given jurisdiction in an illegal manner or with
irregularity. The similarity between the two is that if the right to appeal is not allowed to the

17
Major. S.S. Khanna v. Brig. F.J. Dillion,1964 AIR 497.

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aggrieved party, he can either file a review application or a revision application based on the
circumstances of the case.
JUDICIAL PRECEDENTS
The Supreme Court in the case of Lily Thomas vs Union of India18 laid down that the word
„review‟ is, “the act of looking, offer something again with a view to improve.” In the case of
Patel Narshi Thakeshi vs Pradyumansinghji Arjun Singhji19 it was stated that the power of
review is not an inherent power which means that it has to be conferred by law by
specifically stating or necessarily implied. Review cannot be said to be an appeal in disguise.
Lily Thomas case quoted that „law has to bend before justice‟20 It stated that if the judgment
on the case was made under mistake and that the earlier judgment would not have been
passed which would have prevented a miscarriage of justice, the Court would not have to
correct the error made in the judgment.
The concept of review petition is also accepted in English Courts. In the case of R vs IRC Ex
parte Preston21 it was stated by Lord Scarman that judicial review as a remedy shall not be
made available if there are other remedies present. It cannot be compared to an appeal. When
appeal procedures are already provided, the collateral process of judicial review should be
used rarely.
The High Court of Madhya Pradesh in the case of Principal Commissioner of Customs vs
M.S.S Foods Processors22 held that a review petition can be made only when there is an error
or mistake made on the face of record or there is some other sufficient reason. This error must
be apparent and should be made out without conducting further detailed examination. Re-
examining a case without any apparent error is not permissible and can be challenged under
section 114 and order 47 Rule 1 of the CPC and article 226 of the Constitution of India.
The Supreme Court in Asstt. Commissioner of Income Tax vs Saurashtra Kutch Stock
Exchange Ltd.23 said that an error cannot be said to be apparent or on the face of it if one has
to look beyond records to find whether the judgment passed was correct or not. It does not
have to be something which needs a long-drawn reasoning as to why there is an error, rather
something can be striked on one look. Also, in the case of JSW Energy Limited vs Union of
India24 it was held by the Hon’ble Delhi High Court that review does not itself concern with
the judgment but the process of making the decision/judgement. It is the review of the
manner the judgment was made and not what was made.
Lastly, in the case of Board of Control for Cricket in India vs Netaji Cricket Club25, it was
held that Order 47 Rule 1 of CPC provides for filing of an application for review which shall
be maintainable not only on discovery of any new evidence or if there is an apparent error on
the face of record, but also if there is any other sufficient reason or necessary on the account
of same mistake. Thus, a mistake made by the court would naturally be called for a review of

18
Lily Thomas vs Union of India, (2000) 6 SCC 224.
19
Patel Narshi Thakeshi vs Pradyumansinghji Arjun Singhji, (1971) 3 SCC 844.
20
Lily Thomas vs Union of India, (2000) 6 SCC 224.
21
R vs IRC Ex parte Preston, (1985) 4C 835 = (1985) 2 A 11 ER 327 = (1985) STC 282.
22
Principal Commissioner of Customs vs M.S.S Foods Processors, 2017 (7) G.S.T.L 394 (MP).
23
Asstt. Commissioner of Income Tax vs Saurashtra Kutch Stock Exchange Ltd, 2008 (230) E.L.T 385 (SC).
24
JSW Energy Limited vs Union of India, 2019 (17) G.S.T.L 198 (Bom.).
25
Board of Control for Cricket in India vs Netaji Cricket Club, (2005) 4 SCC 741.

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the order. The term „sufficient reason‟ under Order 47 Rule 1 is wide enough to be
interpreted in a misconception of fact or law. The doctrine of review lies under the doctrine of
„actus curiae neminem gravabit‟ which means that the act of court shall prejudice no one.
CONCLUSION
In this paper, we have defined the meaning of the term „Review‟ under the Civil Procedure
Code. It is mentioned under section 114 and Order 47 of the CPC Order XLVII mentions the
nine rules which imposes conditions on review. To say, the power of review is the power
vested to the courts by law and is a substantive power. The objective of the power of review
is to ensure that justice is served and that no innocent is falsely accused or harmed. To rightly
say, the law has to bend before justice. The re-examination of the facts and judgment of the
case is done in the same court and in front of the same judge (or their successor-in-office)
who gave the earlier judgment. The most important condition is the discovery of a new or
important matter or evidence which wasn‟t mentioned before and now is necessary in the
proceedings. Any mistake or error of law is one of the grounds in which a review petition can
be filed, or any other sufficient reason which can be interpreted to be deemed fit by the
judicial committee.
The right of review judgment is an exception to the Latin term „functus officio‟ which means
that once a judgment is passed by the court, the case cannot be reopened and the judgment is
binding on both the parties. On the application filed by an aggrieved person, the proceeding
for review of judgment can be initiated. The review petition, when a decree is passed by High
court can be made to that judge, or their successor. And when a decree is passed by any court
other than High Court, the review application shall be filed to the same judge who gave the
judgment regarding the case or their successor in office. To conclude, the power of review is
the power where a court review its own judgment and ensures that justice is served.

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BIBLIOGRAPHY
CONSTITUTION
1. Constitution of India, 1950
STATUES
1. Civil Procedure Code, 1908
2. Limitations Act, 1963
BOOKS
1. C.K. Takwani, Civil Procedure & Limitation, 8th Edition, 2019.
CASES CITED
1. Asstt. Commissioner of Income Tax vs Saurashtra Kutch Stock Exchange Ltd, 2008
(230) E.L.T 385 (SC).
2. Board of Control for Cricket in India vs Netaji Cricket Club, (2005) 4 SCC 741.
3. Common Cause, A Registered Society v. Union of India, (1999) 6 SCC 667.
4. Delhi Admn. v. Gurdip Singh Uban, (2000) 7 SCC 296.
5. Gujarat University v. Sonal P. Shah, AIR 1982 Guj 58.
6. Jasbhai Motibhai v. Roshan Kumar, (1976) 1 SCC 671.
7. JSW Energy Limited vs Union of India, 2019 (17) G.S.T.L 198 (Bom.).
8. Lily Thomas v. Union of India, (2000) 6 SCC 224.
9. Major. S.S. Khanna v. Brig. F.J. Dillion,1964 AIR 497.
10. Nundo Lal v. Punchanon Mukherjee, AIR 1918 Cal 618.
11. Patel Narshi Thakeshi vs Pradyumansinghji Arjun Singhji, (1971) 3 SCC 844.
12. . Principal Commissioner of Customs vs M.S.S Foods Processors, 2017 (7) G.S.T.L
394 (MP).
13. R vs IRC Ex parte Preston, (1985) 4C 835 = (1985) 2 A 11 ER 327 = (1985) STC 282
14. Raja Shatrunji v. Mohd. Azmat, (1971) 2 SCC 200.
15. Ram Baksh v. Rajeshwari Kunwar, AIR 1948 All 213.
16. Reliance Industries Ltd. v. Pravinbhai, (1997) 7 SCC 300.
17. Shevdeo Singh v. State of Punjab, AIR 1963 SC 1909.
18. Sushil Kumar v. State of Bihar, (1975) 1 SCC 774.
19. Thungabhadra Industries Ltd. v. Govt. of A.P, AIR 1964 SC 1372.
20. Usha Ranee Banik vs Hardas, AIR 2005 Gau 1.

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